Louis A. and Christine Cox - Page 9

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               Mr. Skidmore completed his consideration and calculated                
          monthly net income of $8,550 (total income of $14,457 less                  
          allowable expenses of $5,907), for a collection potential from              
          petitioners’ future income over 60 months of $513,000, plus net             
          realizable equity in assets of $34,161.  In this computation,               
          Mr. Skidmore allowed only standard housing expenses of $1,299 as            
          documentation relating to the $7,081 was unclear and the cost of            
          maintaining a home was not converted to a business expense merely           
          by use as security for alleged business loans.  He also                     
          disallowed the life insurance expenses as nothing showed that it            
          was not a personal asset benefiting petitioners and completely              
          under their control.  Mr. Skidmore did not find that any                    
          collection alternatives were appropriate on the record presented,           
          but he did conclude that the addition to tax for failure to file            
          timely for 1999 should be abated.                                           
               On November 17, 2003, petitioners sent a letter to                     
          Mr. Skidmore responding to the conclusions in his October 31,               
          2003, letter.  Therein they presented further argument regarding            
          compliance, housing expenses, and collection alternatives.  They            
          emphasized their alleged efforts to return to compliance,                   
          defended their housing costs or alternatively requested a year to           
          modify any expenses deemed excessive, and repeatedly advocated              
          for placement of their accounts in “currently uncollectible                 
          status”, acknowledging that neither an installment agreement nor            






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