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After analysis of the Form 433-A, Ms. Magee advised
petitioner that, assuming the expenses claimed on the Form 433-A
could be substantiated, petitioner would appear to qualify for an
installment agreement with monthly payments of $700. In arriving
at her determination with respect to a $700 payment, Ms. Magee
took into account the following specific monthly amounts: (1)
the $2,600 of claimed disability insurance income; (2) $782 for
food, clothing, and miscellaneous expenses pursuant to IRS
National Standards (although petitioner claimed only $500 on her
Form 433-A); (3) the $300 claimed for housing and utilities; (4)
the $100 claimed for transportation; (5) the $620 claimed for
health care; and (5) the $98 claimed for insurance. The claimed
charitable contribution was not allowable under IRS procedures.
When petitioner objected to a $700 payment on grounds that it
would negatively impact her ability to make an appropriate tithe
to her church, Ms. Magee pointed out that disallowance of the
contribution amount was largely offset by allowance of an
additional $282 for food, clothing, and miscellaneous expenses.
The collection hearing concluded with an understanding that
petitioner would provide the remaining necessary substantiation
and would advise Ms. Magee by January 15, 2004, if she was
interested in accepting a $700 monthly installment agreement.
Having received no further response from petitioner,
respondent on January 23, 2004, issued to petitioner the
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