Lawrence Jay Russ - Page 6




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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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