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with business inventory, accounts receivable, vehicles
and cash on hand. Future income value was set at
$11,220.00.
The taxpayer was given opportunity to protest the
examiner’s findings, but provided no additional infor-
mation to support reduction in the values assigned.
* * * * * * *
The examiner determined future income value based on an
excess of $110.00/month, but failed to make contingent
allowances for health care or life insurance, both of
which should have been factored into necessary living
expenses. Since it was anticipated that the cost of
these items would exceed the $110.00 projected excess
per month, future income value was eliminated as unre-
alistic for the taxpayer’s situation. * * *
The examiner’s findings were shared and discussed with
the taxpayer’s representative, who advised that he had
related to the taxpayer that the offer would not be
acceptable due to his equity position in real property.
Based on the taxpayer’s lack of a meaningful response
to these findings, I anticipate that he would be disin-
clined to withdraw the offer.
CONCLUSION
I recommend that the proposed rejection be sustained.
[Reproduced literally.]
On April 17, 2006, respondent issued to petitioner a notice
of determination with respect to petitioner’s unpaid 2001 income
tax liability and petitioner’s unpaid 2002 income tax liability.
That notice stated in pertinent part:
Summary of Determination
You submitted a timely Collection Due Process Hearing
and a conference was held to discuss alternatives to
the filed Notice of Federal Tax Lien. As a result of
that conference, you submitted an Offer-in-Compromise,
which was investigated, but could not be recommended
for acceptance because you demonstrated ability to pay
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