Barry and Sherry Blondheim - Page 7

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          disposable income of $4,746.  She calculated that petitioners               
          could pay $227,808 from their future income.7  In sum, Cochran              
          concluded, petitioners’ net realizable equity in assets and                 
          future income equaled $932,844.                                             
               On July 22, 2005, Appeals issued petitioners a notice of               
          determination sustaining the proposed levy.  The notice concludes           
          that petitioners’ $83,213 offer-in-compromise is not an                     
          appropriate collection alternative to the proposed levy.  The               
          notice, citing Internal Revenue Manual (IRM) sections 5.8.11.2.1            
          and 5.8.11.2.2, states that petitioners’ offer does not meet the            
          Commissioner’s guidelines for consideration as an offer-in-                 
          compromise to promote effective tax administration on the basis             
          of economic hardship or equity and public policy.  Cochran noted            
          that since petitioners had not specified the basis on which they            
          were making their offer, she considered it under both economic              
          hardship and equity and public policy grounds.                              
               As to petitioners’ offer-in-compromise to promote effective            
          tax administration due to economic hardship, the notice states:             
               Considered under economic hardship, the taxpayers have                 
               the ability to pay all amounts owed from either their                  
               assets or their income stream and still have assets and                
               an income stream remaining worth over $630,000.  The                   
               amount being offered by the taxpayers represents 8% of                 
               the taxpayers’ Reasonable Collection Potential (RCP).                  



               7 Cochran arrived at $227,808 by multiplying petitioners’              
          monthly disposable income of $4,746 by a factor of 48.                      




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