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433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, and a Form 433-B, Collection
Information Statement for Businesses, in order to submit an
offer-in-compromise for his tax liabilities.
On July 8, 2004, petitioner submitted a Form 656, Offer in
Compromise, along with two different Forms 433-A (both dated June
1, 2004) and a Form 433-B for his professional corporation.
Petitioner submitted the offer on the basis of “doubt as to
collectibility”. Petitioner was not then, and is not now,
contesting his 1996-2002 income tax liabilities. Petitioner
offered to pay $30,000 to compromise his 1996-2002 tax
liabilities. This was a short-term deferred payment offer
payable in monthly installments of $1,250 for 24 months.
On one of the Forms 433-A, petitioner indicated that he
operated David L. Samuel, M.D., P.C., and identified this
corporation as his employer for the prior 4 years. Petitioner
listed his assets as $1,409.89 in a checking account, a house
valued at $330,000 (with a loan balance of $322,025), and
furniture/personal effects worth $10,000. Petitioner indicated
that he was the plaintiff in a $25,000 civil lawsuit for unpaid
wages. Petitioner showed his only source of income as monthly
wages of $7,963. Petitioner reported monthly expenses of: $976
for food, clothing, and miscellaneous (noted as the statutory
allowance); $1,024 for housing and utilities (noted as the
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Last modified: November 10, 2007