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compromise their reported $298,003 liability. The offer was
limited to a claim of effective tax administration because
petitioners had sufficient assets to pay their tax liability in
full. Petitioners supplemented their offer with a completed Form
433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, four letters totaling approximately 65
pages, and volumes of documents. The Form 433-A reported that
petitioners owned assets with a total current value of
$1,388,757, inclusive of the following:3
Assets Current value
Cash in accounts $46,441
Cash value of life insurance 12,707
Pensions & IRA 491,121
Vehicles:
2000 Cadillac Escalade 11,975
1984 Subaru Brat 138
Real estate (residence) 1136,800
Real estate (Oregon property) 96,693
Real estate (other properties) 588,882
Furniture/personal effects 4,000
1,388,757
1 Petitioners reported on Form 433-A that this
figure represents 80 percent of their home’s appraised
value.
The Form 433-A also reported that petitioners owed $9,131 on the
Cadillac Escalade, $103,482 on their residence, $166,041 on their
various other properties, and had taken a $10,000 loan against
3 Form 433-A states that each asset reported on the form
should be valued at its “Current value”, defined on the form as
“the amount you could sell the asset for today”.
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Last modified: May 25, 2011