Ronald W. Oman - Page 3

                                        - 3 -                                         
          Petitioner also struggled with alcohol, drugs, and depression,              
          for which he entered rehabilitation in the fall of 2003.                    
               As of 2004, petitioner’s outstanding tax liabilities for the           
          years 1990, 1993, 1994, 1996, 1997, 1999, 2000, and 2001 totaled            
          $169,145.97.  On February 9, 2004, respondent received from                 
          petitioner a Form 656, Offer in Compromise, offering to pay                 
          $1,000 based on doubt as to collectibility.  Petitioner also                
          provided a Form 433-A, Collection Information Statement for Wage            
          Earners and Self-Employed Individuals, indicating that he was               
          unemployed, lived with friends, received money from his parents             
          “from time to time” and had no assets.                                      
               Respondent thereafter evaluated petitioner’s offer,                    
          preparing, inter alia, a “Full Pay Worksheet” dated February 17,            
          2004, and income/expense and asset/equity tables dated July 16,             
          2004.  The worksheet indicated that petitioner’s total ability to           
          pay was zero and stated that “Initial Analysis indicates a Low-             
          Income Taxpayer that can’t pay with assets at this time”.  The              
          income/expense table reflected that petitioner had monthly income           
          and allowed expenses of $653 and $1,012, respectively, for a $359           
          monthly negative cashflow, and that “the amount that could be               
          paid” was zero.  The asset/equity table showed that petitioner              
          had a “total minimum value” of zero.                                        
               Nevertheless, respondent rejected petitioner’s $1,000 offer-           
          in-compromise because petitioner had “an egregious history of               






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011