- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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