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Hi, I edited the question a bit.  This is all about home equity as viewed by IRS in Offer in Compromise process. I am US citizen, wife is foreign, with ITIN, but not working at moment. I am trying to do OIC paperwork, but looks like I will get flat out denied if the IRS has an angle on the foreign apartment in wife's name, since the equity is more than the debt. So trying to find some rationale as to placing the apartment in a viewpoint from which its equity is not considered realizable by the IRS.