- 4 -
The disagreement between petitioners and respondent’s
Appeals officer focused on whether certain alleged life insurance
and medical and drug expenses should be treated as discretionary
or as nondiscretionary expenses and on whether petitioners had
adequately established that they actually were incurring and
paying the expenses being claimed. During the Appeals Office
hearing, petitioners did not submit the documentation necessary
to substantiate their payment of the disputed expenses.
The chart below sets forth the respective amounts
petitioners claim and respondent would allow for life insurance
and medical and drug expenses:
Type of Expenses Petitioners Respondent
Life Insurance $2,311 $ 500
Medical and Drug 1,553 1,200
Petitioners’ alleged life insurance expenses are based on
whole life insurance policies on the life of each petitioner.
Respondent’s offer-in-compromise guidelines allow taxpayers’
expenses only for term life insurance coverage. See
2 Administration, Internal Revenue Manual (CCH), sec. 5.15.1.10,
at 17,662 (May 1, 2004).
Under section 6330, where a taxpayer’s underlying tax
liability is not in dispute, our standard of review over
respondent’s Appeals Office’s determination on a taxpayer’s
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011