David L. Samuel - Page 1
T.C. Memo. 2007-312
UNITED STATES TAX COURT
DAVID L. SAMUEL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8431-05L. Filed October 15, 2007.
P filed a petition for judicial review in response
to R’s determination to proceed with collection by lien
and/or levy of assessed income tax liabilities, plus
additions to tax and interest, for 1996-2002. R’s
settlement officer rejected P’s offer-in-compromise
because it was not a viable alternative to collection.
The settlement officer, applying guidelines established
by the Internal Revenue Manual, determined that P
should include in the amount of his offer-in-compromise
the value of certain “dissipated assets”, which,
because of the dissipation, became unavailable for
payment of P’s delinquent income tax obligation. The
settlement officer required this inclusion,
notwithstanding that some of the assets had been used
for proper purposes.
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Last modified: November 10, 2007