Henry M. Lloyd - Page 11




                                       - 11 -                                         
                    RE: Offer In Compromise -- Henry M. Lloyd * * *                   
                         and Henry M. Lloyd, P.C. * * *                               
                  *       *       *       *       *       *       *                   
                    This letter and its attachments constitute revised                
               Offers In Compromise (OIC) for the two taxpayers iden-                 
               tified above.                                                          
                    In our telephone discussion of December 22, you                   
               described certain things which needed to be done in                    
               order for the Service to consider the revised offers.                  
               This cover letter describes how everything you sought                  
               has been accomplished.  The attached Forms 656 contain                 
               the actual OIC’s.[11]                                                  
                  *       *       *       *       *       *       *                   
               Court-Ordered Payments                                                 
                    You advised me that your computation of Reasonable                
               Collection Potential, which indicates Mr. Lloyd has the                
               ability to pay monthly installments of $1,304, includes                
               no consideration of the cost of supporting his children                
               or providing for their education, because we had pro-                  
               duced no evidence that he was required by a court order                
               to pay such amounts.  I apologize if you asked for the                 
               court order and I neglected to supply it – I did not                   
               understand that such a request had been made.                          
                    The Marital Settlement Agreement between Mr. Lloyd                
               and his ex-wife is attached for your use.  It imposes a                
               number of financial obligations on Mr. Lloyd, including                
               the provision of health insurance and education, both                  
               of which Mr. Lloyd is currently paying for.  If you add                
               these obligations to the other Necessary Living Ex-                    
               penses on your worksheet, you will see that they to-                   
               tally eliminate Mr. Lloyd’s ability to make any in-                    

               11The record does not contain Forms 656 referred to in Mr.             
          Silverberg’s January 12, 2004 letter.  That is because the                  
          declaration by Mr. Silverberg filed in support of petitioner’s              
          response to respondent’s motion indicates that he was unable to             
          locate such forms.  (Petitioner filed a response to respondent’s            
          motion, a declaration by Mr. Silverberg in support of that                  
          response, and a supplement to that response consisting of a                 
          declaration by petitioner.  We shall refer collectively to those            
          filings by petitioner as petitioner’s response.)                            





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