- 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...)Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011