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life of the collection period. Consequently, the offer was
rejected.4
Settlement Officer Alls explained to petitioner Donald A.
Singer that the offer was rejected because petitioners had the
ability to pay their tax liability in full over the life of the
collection period. Settlement Officer Alls proposed a collection
alternative in the form of an installment plan requiring a
$10,000 downpayment and monthly payments of $275. She orally
requested that petitioners respond to her offer or propose an
alternative method for paying the full amount by July 31, 2003.
However, petitioners did not respond. They neither offered an
alternative payment plan nor submitted any additional information
regarding changed financial circumstances.
Having reached no agreement on an installment payment
amount, respondent issued the notice of determination to
petitioners by certified mail on December 5, 2003. Subsequently,
petitioners timely petitioned the Court in the instant lien or
levy action, requesting lower monthly installment payments on the
basis of changed financial circumstances. The petition stated:
Seek relief in the form of a reduction in the
monthly payment set forth in the notice of
determination dated 12/52003 [sic]. Since the
submission of our Offer In Compromise and the notice of
determination our monthly expenses have increased.
Monthly term life insurance premiums have increased
4This determination was summarized in a “Rejection Narrative
Doubt as to Collectibility” dated Nov. 13, 2003.
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