- 10 - From the refinance of his residence petitioner received a net amount of $25,158. Petitioner used $11,000 to pay delinquent child support and transferred the remaining $14,158 to his professional corporation (which was used to pay a supplier, malpractice insurance, delinquent telephone charges, and payroll). Also in his response to the preliminary determination, petitioner asserted that the attorney’s fees were an allowable necessary expense because they were necessary for his representation before the IRS with respect to his current tax matters. He closed the letter by saying he thought negotiation of an offer-in-compromise was possible given his belief that he did not dissipate assets and that he is allowed to claim attorney’s fees as an expense. On March 8, 2005, the settlement officer sent a letter to petitioner stating that her positions on the dissipated assets and attorney’s fees remained unchanged. Petitioner did not respond to this letter and never increased his offer. On April 8, 2005, Appeals issued petitioner a notice of determination sustaining the proposed collection actions. The summary of determination concluded that petitioner’s proposed collection alternative was not a viable option. The notice indicated Appeals’ finding that the IRS could collect more than the $30,000 offer. The notice referred to the discovery of thePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: November 10, 2007