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or no value. Petitioner also gave details regarding the
abovementioned lawsuit against his previous employer to collect
back wages. He said that billings show that he is entitled to
$60,000 plus interest.
On February 10, 2005, the settlement officer sent petitioner
a letter with her preliminary determination. She stated her
position that petitioner had “dissipated assets” with a disregard
of his outstanding tax liabilities when he sold his interest in
FMC and refinanced his home. She reasoned that at the time the
transactions occurred, the outstanding assessed balances due to
the IRS exceeded the amounts realized from the dissipated assets.
In addition, she noted that none of the funds were remitted to
the IRS, and she took the position that petitioner did not use
any of the funds for necessary expenses. She said that unless
petitioner increased his offer to $163,158 ($30,000 initial offer
amount plus 100 percent of the dissipated asset values), she
would assume that petitioner was not interested in pursuing the
matter further, and that she would recommend that Appeals issue a
notice of determination.
The settlement officer indicated that her preliminary
determination did not represent a final amount determined to be
an acceptable offer. She noted that she did not include in the
reasonable collection potential calculation any amounts for
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