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taxes and the FICA tax. Officer Clark computed petitioners’ FICA
tax from Mrs. Diffee’s earnings statement for the first 16 weeks
of 2006.
Finally, Officer Clark decreased petitioners’ health care
expense. His decision was based on several factors. First,
petitioners did not provide Officer Clark with any documentation
or explanation regarding the $700 health care expense claimed on
the Form 433-A. Second, petitioners did not claim any itemized
deductions for medical expenses on their Federal income tax
return for 2005. Because petitioners failed to present any
evidence of Mr. Diffee’s medical condition during the section
6330 hearing, Officer Clark did not abuse his discretion by
reducing petitioners’ health care expense.
The record discloses that Officer Clark adjusted his
calculations based on information he received from petitioners.
During a conference with petitioners’ representative, Officer
Clark agreed to increase petitioners’ expense by $500 per month
for Mrs. Diffee’s meals on the road. This allowance reduced
petitioners’ monthly payment under the installment agreement to
$1,877.8 However, petitioners refused Officer Clark’s proposed
changes to their installment agreement and requested that he
issue the determination letter.
8Officer Clark originally proposed a monthly payment of
$2,377.
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Last modified: November 10, 2007