Roger D. and Mary M. Catlow - Page 9

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               these possible future expenses are general projections                 
               from the taxpayers’ representative and may never, in                   
               fact, be incurred.  The present offer, therefore, must                 
               be considered within the framework of present facts.                   
               The taxpayers have an ability to pay substantially more                
               than the amount being offered, as per the guidelines of                
               Internal Revenue Manual 5.8.5.3.1.  The taxpayers’                     
               circumstances have been documented and considered but                  
               are insufficient to permit acceptance of an offer                      
               amount that is 18% of the RCP [reasonable collection                   
               potential] ($35,000/$193,438).                                         
          As to petitioners’ offer-in-compromise to promote effective tax             
          administration, the notice states:                                          
               Analysis of the taxpayers’ finances shows that the                     
               taxpayers’ equity in assets plus present and future                    
               income are less than the assessed amounts to be                        
               compromised.  The taxpayers, therefore, fail to meet                   
               the requirements for consideration of an offer in                      
               compromise based on Effective Tax Administration, as                   
               per the guidelines of Internal Revenue Manual                          
               5.8.11.1(3).                                                           
          The notice further states as to Cochran’s balancing of efficient            
          collection with the legitimate concerns of taxpayers that                   
               The taxpayers’ concerns about the proposed collection                  
               action generally fall within two areas: (1) pending                    
               litigation (the innocent spouse case and the interest                  
               abatement case) and (2) a viable collection alternative                
               in the form of their $35,000 offer in compromise.                      
               The Settlement Officer has balanced the taxpayers’                     
               first area of concern by researching both cases.  The                  
               Settlement Officer confirmed that on February 25, 2005                 
               a stipulation has [sic] been entered into [sic] Tax                    
               Court regarding the taxpayer-wife’s innocent spouse                    
               case.  In that stipulation, with [sic] the taxpayer-                   
               wife conceding [sic] that she is not entitled to relief                
               under IRC � 6015(b), (c), or (f), and that she waives                  
               the restrictions of IRC � 6015(e)(1)(B)(i).  The                       
               Settlement Officer also researched the taxpayers’                      
               interest abatement  case and was unable to locate                      
               evidence that this case has been considered by IRS to                  





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