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and 64 years old, respectively. Driver made the following
calculation in determining that petitioners’ net realizable
equity in assets was $161,844:
Assets and Liabilities Reported on Form 433-A
IRAs:
Vanguard 25,529
Zurich 31,161 56,690
Stock of GE/Motorola 8,165
Home 160,648
Less mortgage loan balance 103,982 56,666
121,521
Other Assets
IRA: Indianapolis Life 138,823
Lots in Apache and Pima Counties 21,500
40,323
Net realizable equity in assets 161,844
1 This amount equals 70 percent of the $55,462 balance
in this account as of Sept. 30, 2004.
2 This amount equals $1,300 less than the total assessed
values of these lots.
Driver calculated petitioners’ reasonable collection potential to
be $161,844, the same amount as their net realizable equity in
assets; in other words, Driver determined that petitioners had no
disposable income.
On January 26, 2005, Appeals issued petitioners the notice
of determination sustaining the proposed levy as to 1984, 1985,
1986, and 1991. The notice reflects Driver’s conclusion that
petitioners’ offer of $11,552 was inadequate under the applicable
guidelines and that the proposed levy balances the need for the
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