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petitioners' reported monthly expense for housing and utilities
by $50. The net effect of the offer specialist's adjustments to
petitioners' monthly necessary living expenses was to reduce them
from $7,455 to $5,514.
Overall, the offer specialist determined that petitioners
had $2,813 in monthly future income available to pay off their
tax liabilities, as compared to petitioners' reported figure of
$265. The offer specialist further determined that petitioners
could pay this amount for 59 months, resulting in aggregate
payments out of future income of $165,967.
The foregoing calculations produced a reasonable collection
potential of $207,567; i.e., $41,600 in net realizable equity
plus $165,967 in future income. In her final report, the offer
specialist noted that petitioners also had some interests in
family corporations, interest in real property referred to as the
B. Lemann Building, and possibly life insurance. She did not
assign any value to these assets or rely upon them in determining
petitioners' reasonable collection potential.5 The offer
specialist concluded that petitioners had failed to demonstrate
any special circumstances that would justify calculating their
reasonable collection potential outside the prescribed
guidelines. Because the reasonable collection potential of
5 The offer specialist also noted that petitioners had
previously entered into an installment agreement on which they
had defaulted.
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Last modified: May 25, 2011