- 5 - Respondent’s Appeals officer specifically requested additional information to establish whether petitioner had received an ownership interest in the Michigan property under the 2001 divorce decree. Respondent’s Appeals officer considered documents submitted on petitioner’s behalf, including financial information, made an extensive analysis of petitioner’s finances and provided a copy thereof to petitioner. At the conclusion of the Appeals Office collection hearing, respondent’s Appeals officer determined that petitioner had the ability to pay in full her total cumulative $44,383 outstanding 1996, 2000, 2001, 2002, and 2003 Federal income tax liabilities within the balance of the 10-year collection period of limitations. In particular, respondent’s Appeals officer concluded that petitioner in her 2001 divorce proceeding had received an ownership interest in the Michigan property with a value of $25,000. This interest constituted, for purposes of respondent’s consideration of petitioner’s OIC, a dissipated asset that should have been included in the financial information submitted to respondent on petitioner’s behalf in connection with petitioner’s OIC. Accordingly, respondent’s Appeals officer concluded that a minimally acceptable OIC from petitioner would have to include the $25,000 value of petitioner’s interest in the Michigan property.Page: Previous 1 2 3 4 5 6 7 8 NextLast modified: March 27, 2008