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During the taxable years in issue through the time that the
present motions were heard, petitioner resided with his mother in
her home. The record contains a letter dated August 24, 2004,
and signed “Linora Smith” which states: “Wayne Smith has paid
$300 a month rent in cash for approximately the past three-and-
one-half years.”
With respect to the substantiation of the above expenses,
the record contains voided photocopies of personal money orders
drafted on an account held with Central Communications Credit
Union dated January through March of 2005. The “Pay to the Order
of” line on each of these money orders has been filled in by
hand, and neither the amounts reflected in these orders nor their
payees correspond exactly to the expenses listed above.
Finally, and with respect to additional, “special”
circumstances, the Explanation attached to the original OIC
states that petitioner, at 56 years old, “is unable to find any
worthwhile work”, and that he previously underwent “two
angioplasty procedures.”
Collections Due Process Hearing
A CDP hearing occurred between petitioner’s representative
and the Internal Revenue Service (IRS) on May 11, 2005. At that
hearing, petitioner’s representative restated the OIC in the
amount of $9,407.60, and also proposed a second, alternative OIC,
whereby the IRS could levy on petitioner’s then-existing accounts
to collect the full payment for the periods covered by the
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Last modified: March 27, 2008