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of $201,191. Petitioners checked the "Doubt as to
Collectibility" box as the basis on which they believed they were
entitled to be considered for an offer-in-compromise.
The Appeals officer forwarded the offer-in-compromise to an
offer specialist for review. By letter dated May 7, 2002, the
offer specialist informed petitioners that an acceptable offer
amount would consist of both equity in assets and some portion of
"future income" available to pay taxes; i.e., gross income less
necessary living expenses. The offer specialist further advised
that her preliminary calculations showed a reasonable collection
potential significantly higher than the offer petitioners had
made. The offer specialist's administrative file notes of the
same day indicate that she had preliminarily computed
petitioners' future income as $2,713 per month for 48 months, or
$130,224.
The offer specialist's notes record that on May 3, 2002, she
discussed with Mr. Lemann the monthly credit card expense of
$1,600 reported by him on the revised Form 433-A, and advised him
that this expense was not allowable in computing future income.
On May 7, 2002, the offer specialist sent Mr. Lemann her
preliminary income and expense computations in which she noted
that, for purposes of evaluating petitioners' offer-in-
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