- 12 - 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.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007