William H. and Jo Anne Lindley - Page 8

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                Expense item               Monthly Expense                            
                Food, clothing and misc.   $2,450                                     
                Housing                    2,421                                      
                Transportation             1,260                                      
                Health care                250                                        
                Taxes                      2,038                                      
                Life insurance             105                                        
                Other secured debt         652                                        
                Other expenses             709                                        
                Total                      9,885                                      

          The other expenses included $309 paid for their son’s private               
          schooling and $400 in attorney’s fees paid to the Pearson and               
          Merriam law firm for representation in Hoyt-related litigation.             
               In one of the letters, petitioners state that they are                 
          offering to pay $40,413 “for all Hoyt-related years to be paid in           
          one lump sum payment * * *.  This offer assumes that the IRS will           
          collect less than the Reasonable Collection Potential * * * based           
          on special circumstances and/or Effective Tax Administration.”              
          The letter also included “background” information regarding the             
          Hoyt partnerships and set out petitioners’ “special                         
          circumstances”.                                                             
               In the remaining two letters, petitioners provided more                
          “background” information and argued:  (1) Their case was a                  
          “longstanding” case; (2) the delay was attributable to the                  
          criminal investigation of Hoyt; (3) interest should be                      





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Last modified: May 25, 2011