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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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Last modified: May 25, 2011