- 5 - 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-Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011