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By letter dated March 16, 2005, the settlement officer
informed petitioner that she had adjusted his monthly expenses to
meet the national standard for one person.6 As a result, the
settlement officer determined that petitioner was able to make
monthly payments of $1,475. The settlement officer also denied
petitioner’s request for abatement of interest and for relief
from the additions to tax. The settlement officer gave
petitioner until March 30, 2005, to accept the proposed
installment agreement.
By letter dated March 27, 2005, petitioner rejected the
proposed installment agreement. Petitioner disputed the
settlement officer’s adjustments to his monthly expenses as
reported on his updated Form 433-A, and he inquired whether any
of the AMT that he had paid could be used to offset his unpaid
tax liabilities. By letter dated July 21, 2005, the settlement
officer offered petitioner a reduced installment agreement with
monthly payments of $1,250. She gave petitioner until August 5,
2005, to respond.
By letter dated August 3, 2005, petitioner rejected the
installment agreement and once again requested relief based on
6Respondent informed petitioner that he could claim expenses
for only himself because he did not claim his spouse’s income.
Petitioner never argued that his spouse was unemployed or that he
was otherwise supporting his spouse. However, he did testify
that he was supporting two aging parents and an ill niece. The
record does not disclose any detail of petitioner’s support of
these individuals.
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Last modified: March 27, 2008