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We turn finally to petitioner’s third principal argument.
In petitioner’s response, petitioner argues that the settlement
officer “made no effort to balance the Service’s needs for
efficient collection of taxes against the taxpayers’ legitimate
concern that collection action be no more intrusive than neces-
sary.”
We have found that, assuming arguendo that the settlement
officer had calculated the “future income” component of peti-
tioner’s RCP by using petitioner’s average monthly wage income
for the seven-year period 1998 through 2004 or his average
monthly wage income for the twelve-year period 1993 through 2004,
petitioner’s RCP nonetheless would have exceeded the amount
(i.e., $139,776) that petitioner offered in petitioner’s June 24,
2005 offer-in-compromise. In the case of the use of such seven-
year period, petitioner’s RCP would have exceeded petitioner’s
offer by $797,688.84. In the case of the use of such twelve-year
period, petitioner’s RCP would have exceeded petitioner’s offer
by $787,961.64. As discussed above, in order to be considered
for acceptance, an offer based on “Doubt as to Collectibility”,
the basis on which petitioner submitted petitioner’s June 24,
2005 offer-in-compromise, generally must equal or exceed the
taxpayer’s RCP. Id. Regardless of whether the “future income”
component of petitioner’s RCP is calculated on one of the two
bases urged by petitioner or on the basis used by the settlement
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