- 6 - compromise, petitioners' future income was $2,713 for 48 months,3 or $130,224. In a letter to her dated May 14, 2002, Mr. Lemann responded: It seems to me that the future income calculation overlooks two important facts: 1. I am now 60 years of age and may very well not have 4 more years of productivity; 2. Converting that future income potential into a $130,224.00 lump sum is impossible given my financial circumstances. The offer specialist's notes record that she received this letter on May 21, 2002, and that on May 23, 2002, she discussed with Mr. Lemann the special circumstances that would give rise to a departure from the standard computation of future income and gave examples. The offer specialist's notes further record that Mr. Lemann did not provide her with any information that constituted special circumstances. On May 24, 2002, the offer specialist forwarded her final computations of petitioners' reasonable collection potential to the Appeals officer. In computing petitioners' net realizable equity in assets, the specialist accepted petitioners' $125,000 estimate of the value of their residence as reported on their 3 Under Internal Revenue Manual (IRM) guidelines, for purposes of evaluating "cash" offers-in-compromise such as petitioners', future income for 48 months is considered, whereas future income for 60 months is generally used when deferred payment offers-in-compromise (which may include both a lump-sum payment and an installment agreement) are evaluated. IRM, sec. 5.8.5.4 (Nov. 2000).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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