- 62 - 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 settlementPage: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 NextLast modified: March 27, 2008