- 8 - 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.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