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creditors, with the exception of the $15,600 payment to the IRS.
She determined that 100 percent of the $133,158 received from the
dissipated assets should be included in petitioner’s NRE with the
possible exception of the $15,600 paid to the IRS, the $5,000
legal fees incurred in the lawsuit against his former employer,
and the $5,464 paid for child support. She reached this
conclusion despite recognizing that the assets were dissipated
before the offer-in-compromise was made. The settlement officer
did not include any amount for the value of petitioner’s
residence in NRE, having determined that he had no equity. She
also expressed doubt as to whether petitioner reported an
accurate value for his interest in his medical corporation,
noting the comparatively low value of equipment totaling $3,630
given that the business had gross income in excess of $300,000 in
2003. The settlement officer did not account for petitioner’s
interests in his medical corporation or Pontchartrain Lithotripsy
in calculating NRE. The settlement officer determined
petitioner’s future income collection potential to be $946 per
month, which, over 60 months (the multiplier for a short-term
deferred payment offer) amounted to $56,760.
In response to the notice of determination, petitioner filed
a petition with this Court.
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Last modified: November 10, 2007