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). UnlessPage: 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007