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statutory allowance); $50 for health care; $2,470 for taxes;
$2,750 for court-ordered payments (child support); and $250 for
other expenses (later identified as attorney’s fees for
representation in the instant matter). The second Form 433-A
contained the same information as the first, except that it
reported gross monthly wages of $8,144.10 and monthly medical
expenses of $41.20.
The Form 433-B for David L. Samuel, M.D., P.C., reflected
that petitioner was the only shareholder. The total
accounts/notes receivable of the medical corporation was shown as
$87,388.73. The only other assets disclosed on the Form 433-B
were $613.74 in a bank account, $200.22 of cash on hand, and
office furniture valued at $4,000. In the “Investments” section,
petitioner listed one share of Pontchartrain Lithotripsy, LLC,
with a value of $10,000. Total monthly income for petitioner’s
professional corporation consisted of $26,435.20 in gross
receipts and $4,416 in dividends for a total of $30,851.20.
Petitioner reported monthly expenses totaling $33,523.93 for the
professional corporation.
Petitioner’s offer-in-compromise was accepted for processing
and forwarded to respondent’s New Orleans Compliance Office for
investigation.
Petitioner requested a face-to-face hearing at the New
Orleans Appeals Office, to which the IRS agreed. The face-to-
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Last modified: November 10, 2007