- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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