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Assuming arguendo, as petitioner argues alternatively, that
the “future income” component of petitioner’s RCP should have
been calculated by using his average monthly wage income for the
twelve-year period 1993 through 2004, rather than his average
monthly wage income for the three-year period 2002 through 2004,
petitioner’s RCP would be $927,737.64.37 Petitioner’s RCP as so
calculated exceeds the amount ($139,776) in petitioner’s June 24,
2005 offer-in-compromise that petitioner offered to compromise,
inter alia, petitioner’s unpaid liabilities for 1990, 1991, 1992,
1994, 1996, 1997, and 2002. See IRM pt. 5.8.1.1.3(3) (Sept. 1,
2005).
On the record before us, we find that the settlement officer
did not abuse the settlement officer’s discretion in rejecting
the offer of $139,776 in petitioner’s June 24, 2005 offer-in-
compromise.
37The monthly average of petitioner’s wage income for 1993
through 2004 is $6,952.03. See supra note 32. Adding to that
amount petitioner’s other monthly income (i.e., $1,992) and
subtracting petitioner’s allowed monthly necessary living ex-
penses (i.e., $6,243) results in “excess” monthly income of
$2,701.03. That amount of “excess” monthly income multiplied by
48 months results in “future income” of $129,649.44. That amount
of “future income” plus the amount that the settlement officer
calculated as the “net realizable equity” component of peti-
tioner’s reasonable collection potential (i.e., $798,088.20),
which “net realizable equity” component petitioner does not
dispute in petitioner’s response, results in a reasonable collec-
tion potential for petitioner of $927,737.64. See supra note 36.
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