Donald A. and Virginia M. Singer - Page 4

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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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