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On December 6, 2005, the settlement officer held a tele-
phonic conference with Mr. Kauffman. The settlement officer made
the following pertinent entries in her “Case Activity Records”
with respect to that conference:
Telephone conference with POA Mr.Kauffman. We dis-
cussed the OIC and I explained taxpayer RCP is close to
1 million dollars. He wanted to know if the taxpayer
obtain the equity in his real property would I recom-
mend acceptance of the offer. This request was denied
because it appears taxpayer can enter into an install-
ment agreement at a rate of $12,000.00 a month. he
stated that the taxpayer is elder and his business is
no longer at a high point. I explained he is still
working and in good health. We average his last three
years to determine his monthly income. We discussed
the one-year rule in allowing expenses. He requested a
copy of the 433A and the O/S worksheet computation. He
requested time to discuss with client and telephone
conference scheduled for 12/16/2005 @ 10:00AM. Infor-
mation faxed to POA. [Reproduced literally.]
On December 15, 2005, Mr. Kauffman sent a letter to the
settlement officer via facsimile (Mr. Kauffman’s December 15,
2005 letter). In that letter, Mr. Kauffman stated in pertinent
part:
This letter is written as a follow-up to our
several telephone conversations, and in anticipation of
our telephone conference tentatively scheduled for
Friday afternoon. Up to this time, the focus of our
discussions has been on Mr. Lloyd’s income, and specif-
ically how to calculate his average monthly income in a
fair fashion. Enclosed with this letter are the in-
come/expense table which you were kind enough to fax me
last week, and a spreadsheet analysis of Mr. Lloyd’s
income which I have prepared. Before addressing the
enclosed spreadsheet analysis, a few observations about
Mr. Lloyd’s income are in order.
Mr. Lloyd, who is an attorney engaged in the
private practice of law, will be 71 this March. The
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Last modified: March 27, 2008