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that the IRS could not accept the OIC because: (1) Petitioner’s
OIC computation reduced his income available to pay taxes by his
credit card payments, and (2) petitioner had the ability to pay
the full liability over time. The AO offered an installment
agreement as a collection alternative, with monthly payments
designed to pay the entire liability. The proposed installment
amount was $800 per month for 2006 and $1,210 per month beginning
in January, 2007. Petitioner rejected the installment agreement,
asserting that he could not afford the proposed monthly payments.
On October 7, 2005, the AO wrote petitioner a letter
explaining his determination and enclosed an installment
agreement form. The AO determined petitioner’s income history as
follows:
Table 2: Income Earned by Year
Tax Year Income
2000 $88,804
2001 80,004
2002 68,985
2003 77,635
2004 87,637
Petitioner, the OIC examiner, and the AO analyzed
petitioner’s income, expenses, and ability to pay his taxes as
follows:
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Last modified: March 27, 2008