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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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