Henry M. Lloyd - Page 54




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          alia, that specialist’s use of the three-year period 2002 through           
          2004 on which to calculate the “future income” component of such            
          RCP.  We believe that the second offer specialist’s calculation             
          of the “future income” component of petitioner’s RCP on the basis           
          of the three-year period 2002 through 2004, with which the                  
          settlement officer agreed, is supported by part 5.8.5.5 of the              
          IRM (Sept. 1, 2005), which provides:                                        
               5.8.5.5 * * * Future Income                                            
               (1) Future income is defined as an estimate of the                     
                    taxpayers [sic] ability to pay based on an analy-                 
                    sis of gross income, less necessary living ex-                    
                    penses, for a specific number of months into the                  
                    future.  The number of months used depends on the                 
                    payment terms of the offer.                                       
               a. For cash offers -- project for the next 48                          
                         months.                                                      
               b. For short term deferred offers -- project for                       
                         the next 60 months.                                          
               c. For deferred payment offers -- project for                          
                         the number of months remaining on the statu-                 
                         tory period for collection.                                  
                                                                                     
                  *       *       *       *       *       *       *                   
               (3) Consider the taxpayers [sic] overall general situ-                 
                    ation including such facts as age, health, marital                
                    status, number and age of dependents, highest                     
                    education or occupational training, and work expe-                
                    rience.                                                           
               (4) Retired Debts -- A taxpayers [sic] ability to pay                  
                    in the future may change during the period it is                  
                    being considered because necessary expenses may                   
                    increase or decrease.  Adjust the amount or number                
                    of payments to be included in the future income                   
                    calculation, based on the expected change in nec-                 
                    essary expenses.                                                  








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