Daniel O. Abelein - Page 7

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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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