- 4 - 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.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011