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tax liability for 1981 through 1998, and regular interest through
April 15, 1993.” The letter included a description of
petitioners’ medical conditions. Mr. Carter was diagnosed with a
degenerative back problem in 1969 and has problems with both
knees and one hip.9 Mrs. Carter has a congenital birth defect
that affects kidney and bladder function, and she also suffers
from collagenous colitis, sarcoidosis, Wegner’s disease, and
atrial fibrillation. The letter also included a “retirement
analysis”, outlining the need for home repairs and the likelihood
of increased housing and medical costs as petitioners age.
In the remaining letters, petitioners alleged that their
case was a “longstanding” case and argued that interest should be
compromised due to the longstanding nature of the case.
On May 21, 2004, petitioners submitted another letter to Ms.
Cochran, which included 42 exhibits not previously provided.
On September 27, 2004, respondent issued petitioners a
notice of determination. In evaluating petitioners’ offer-in-
compromise, respondent made the following changes to the values
of assets reported by petitioners on the Form 433-A: (1)
Respondent determined that the house was worth $275,250 instead
of $220,200 (the 80-percent quick-sale value reported by
petitioners) and reduced petitioners’ net realizable equity by
9 Mr. Carter also broke his back in a work-related accident
on June 21, 2005, but by the time of trial, he was back to
working full-time.
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Last modified: May 25, 2011