CORNWELL v. COMMISSIONER

Dkt. No. 15013-06L.

94 T.C.M. 336 (2007)

T.C. Memo. 2007-294

Michael D. Cornwell and Hilary J. Iker v. Commissioner.

United States Tax Court.

September 27, 2007.


Attorney(s) appearing for the Case

Michael D. Cornwell and Hilary J. Iker, pro se.

Michael W. Tan, for respondent.


MEMORANDUM OPINION

COHEN, Judge:

This proceeding was commenced in response to three Notices of Determination Concerning Collection Action(s). The issue for decision is whether the settlement officer abused his discretion in determining the amount of an acceptable offerin-compromise (OIC) by including prior overtime earnings in the calculation of reasonable collection potential (RCP). Unless otherwise indicated, all section references are to the Internal...

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