- 23 - 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 payPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: November 10, 2007