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In the remaining three letters, petitioner alleged that he
was a victim of Hoyt’s fraud and asserted various arguments
regarding the appropriateness of an offer-in-compromise.
On May 21, 2004, petitioner submitted another letter to Ms.
Cochran, which included 42 exhibits not provided with the
previous letters.
On November 23, 2004, respondent issued petitioner a notice
of determination. Respondent determined that petitioner had:
(1) Total net realizable equity in his assets of $156,053; (2) an
amount collectible from future income of $1,243,381,8 and (3) a
reasonable collection potential of $1,415,173. Respondent
determined that petitioner was not entitled to an effective tax
administration offer-in-compromise based on public policy or
equity ground because the case “fails to meet the criteria for
such consideration”. Respondent determined that petitioner did
not offer an acceptable collection alternative and that all
requirements of law and administrative procedure had been met.
Respondent concluded that the proposed collection action could
proceed.
In response to the notice of determination, petitioner filed
a petition with this Court on December 29, 2004.
8 Respondent determined that petitioner had monthly
disposable income of $15,739 and multiplied that amount by 79,
the number of months remaining on the collection statute.
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