- 3 -
old, were retired, and had an adult child living with them who
was a dependent for tax purposes. On the second OIC, Mr. Harris
wrote: “As the record will verify, I am re-submitting this Offer
in Compromise which will include basically statements of both our
incomes. As you know Verline, my wife and I are both retired. I
am also submitting copies of health status from our doctors.”
On February 20, 2003, an entry was made on a 10-page
document entitled “ICS History Transcript” (ICS transcript)--
which reflects Mr. and Mrs. Harris’s collection case history.
The entry states that Mr. Harris provided a statement from his
doctor that Mr. Harris has severe osteoarthritis, he is totally
disabled, and he cannot work. It also was noted that Mrs. Harris
provided statements from two doctors. Mrs. Harris was diagnosed
with a “non-Q wave myocardial infarction”. She has a history of
coronary artery disease, class 1 to 11 angina pectoris, a history
of hyperlipidemia even on medication, a history of goiter,
hypothyroidism even on medication, and insulin-dependent diabetes
mellitus with diabetic retinopathy.
An undated and unsigned handwritten document regarding the
reasonable collection potential for Mr. and Mrs. Harris’s 1995,
1996, 1997, 1998, and 1999 tax years, prepared by a revenue
officer,3 lists $574 as available (presumably per month) for
3 According to the ICS transcript, on Jan. 9, 2003, Aisha
Akil was assigned to petitioners’ case. Accordingly, Revenue
(continued...)
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Last modified: May 25, 2011