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cost of his living in the downtown Chicago area because of his
need to entertain clients in his home. Further, petitioner
claims that respondent failed to evaluate petitioner’s option to
file for bankruptcy and the potential discharge of some of the
taxes that respondent seeks to collect by levy.
Respondent, in applying the published guidelines, allowed
petitioner $2,474 per month for basic living expenses, which
petitioner agrees was substantially the same as the amount
provided for under the published guidelines.11 When subtracted
from the $22,000 gross monthly income that petitioner disclosed
in his offer-in-compromise, and in the light of respondent’s
records which showed that petitioner had $302,400 in wages and
$13,400 in nonemployee compensation for tax year 2004,12
respondent concluded that petitioner would be able to pay his by-
then $252,462 tax liability in full over 48 months.
We agree with respondent that petitioner had sufficient
income to meet his basic living expenses as well as to pay his
tax liability in full. Petitioner basically wants the Government
11Respondent allowed $194 per month for transportation; it
appears that the published guidelines allow $329, or a similar
amount, for ownership of one car in Chicago. Petitioner contends
that he should be allowed “the actual expense for his car loan
($870 per month)” instead.
12The record shows that respondent did not consider the
value of dissipated assets in evaluating petitioner’s offer-in-
compromise, although respondent was concerned that such
consideration might have been warranted. See 1 Administration,
Internal Revenue Manual (CCH), sec. 5.8.5.4. at 16,339-6.
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Last modified: November 10, 2007