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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007