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regarding the appropriateness of an offer-in-compromise, and
argued that he was not liable for section 6621(c) interest.
On May 21, 2004, petitioner submitted another letter to Ms.
Cochran, which included 42 exhibits not provided with the May 14,
2004, letters.
On September 23, 2004, respondent issued petitioner a notice
of determination. In evaluating petitioner’s offer-in-
compromise, respondent made the following changes to the values
of assets petitioner reported on the Form 433-A: (1) Respondent
determined that the value of the section 401(k) plan account was
$254,976 instead of $178,483 (the 70-percent value petitioner
reported) and reduced the estimate of petitioner’s net realizable
equity by $47,347 to $207,629 to reflect estimated tax and
penalties; (2) respondent determined that the house was worth
$240,000 instead of $140,000 (the 80-percent quick-sale value
petitioner reported) and reduced the value by the $37,145
outstanding on the mortgage, for net realizable equity of
$229,060; (3) respondent determined that the 1981 Toyota Pickup
had a quick-sale value of $80 instead of de minimis; and (4)
respondent considered only the 1993 Yamaha 225’s quick-sale value
of $760 instead of the fair market value of $950 petitioner
reported. Respondent concluded that petitioner had a total net
realizable equity of $452,714.
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