- 41 -
3 year analysis
Gross Cum. Tax. Average Cum. Avg.
Year Income Income Monthly Monthly
1 2002 200,000 200,000 16,667 16,667
2 2003 329,151 529,151 27,429 22,048
3 2004 71,842 600,993 5,987 16,694
3 year average monthly [24]18,470
On December 16, 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:
POA had faxed a chart requesting that we use the last
seven years to compute the income of the taxpayer. I
explained I would use the last three years because
these years truly reflect the high and low end of his
client’s income. He stated he will talk to his client
and request the case be returned to compliance. A
determination letter will be issued * * *
On February 8, 2006, the Appeals Office issued to petitioner
a notice of determination with respect to petitioner’s unpaid
liabilities for 1990, 1991, 1992, 1994, 1996, 1997, and 2002.
That notice stated in pertinent part:
Summary of Determination
Your offer in compromise was not recommended for accep-
tance because our computation indicates you have the
ability to full[y] pay. We discussed the possibility
of an installment agreement and you disagree with the
monthly payment amount. We did not discuss any other
alternatives for payment. Based on the evidence in the
case file the District’s decision to issue the Final
Notice-Notice of Intent to Levy and Notice of your
Right to a hearing is sustained.
24See infra note 32.
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Last modified: March 27, 2008