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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.
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Last modified: March 27, 2008