T.C. Memo. 2007-294
UNITED STATES TAX COURT
MICHAEL D. CORNWELL AND HILARY J. IKER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15013-06L. Filed September 27, 2007.
Michael D. Cornwell and Hilary J. Iker, pro se.
Michael W. Tan, for respondent.
MEMORANDUM OPINION
COHEN, Judge: This proceeding was commenced in response to
three Notices of Determination Concerning Collection Action(s).
The issue for decision is whether the settlement officer abused
his discretion in determining the amount of an acceptable offer-
in-compromise (OIC) by including prior overtime earnings in the
calculation of reasonable collection potential (RCP). Unless
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Last modified: November 10, 2007