Gary and Johnean Hansen - Page 8

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          concluded, petitioners’ net realizable equity in assets and                 
          future income equaled $611,920 or alternatively $606,734.                   
               On May 12, 2005, Appeals issued petitioners a notice of                
          determination sustaining the proposed levy.  The notice concludes           
          that petitioners’ $90,258 offer-in-compromise is not an                     
          appropriate collection alternative to the proposed levy.  The               
          notice, citing Internal Revenue Manual (IRM) sections 5.8.11.2.1            
          and 5.8.11.2.2, states that petitioners’ offer does not meet the            
          Commissioner’s guidelines for consideration as an offer-in-                 
          compromise to promote effective tax administration on the basis             
          of economic hardship or equity and public policy.  Cochran noted            
          that since petitioners’ representative had not specified the                
          basis on which they were making their effective tax                         
          administration offer, she considered it under both economic                 
          hardship and equity and public policy grounds.                              
               As to petitioners’ offer-in-compromise to promote effective            
          tax administration due to economic hardship, the notice states              
          that “the taxpayers have the ability to meet all their necessary            
          living expenses and to pay all amounts owed from either their               
          equity in assets or their income stream and still have equity and           
          income”.  As to petitioners’ offer-in-compromise to promote                 
          effective tax administration based on equity and public policy,             


               9(...continued)                                                        
          Revenue Manual (IRM) sec. 5.8.5.5.                                          





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