- 19 - petitioners’ reasonable collection potential, we find that those errors were harmless because, even when corrected, petitioners’ reasonable collection potential exceeds their offer amount. 1. Petitioners’ Income and Expenses a. Housing and Utilities Expense Section 7122(c)(2)(A) provides that “the Secretary shall develop and publish schedules of national and local allowances designed to provide that taxpayers entering into a compromise have an adequate means to provide for basic living expenses.” Section 7122(c)(2)(B) provides that the national and local allowances should not be used “to the extent such use would result in the taxpayer not having adequate means to provide for basic living expenses.” Mr. Owens used national and local standards to determine petitioners’ allowable housing and utilities expense, including their second mortgage expense. Petitioners assert that, by not allowing their actual expenses, they will not have adequate means to provide for basic living expenses. However, petitioners did not provide any information to Mr. Owens or to the Court showing that they would be unable to provide for basic living expenses if only allowed the national and local standards. Given the lack of 12(...continued) Petitioners do not dispute respondent’s reduction of their transportation expenses.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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