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petitioners that their offer could not be considered because “The
financial information you provided shows you have sufficient
equity and/or income to pay the liability in full now or by an
installment agreement.”
By a second letter, also dated December 20, 1994, respondent
invited petitioners to attend a workshop on January 17, 1995,
regarding the preparation of offers in compromise. Petitioners
were informed:
The goal of this workshop is to assist you in
preparing an offer in compromise that can be processed
for further investigation by the Service. * * *
Attending the workshop does not guarantee acceptance of
your offer, but it will give you important information
and assistance.
Petitioner attended the workshop.
2. Petitioners’ Second, Third, and Fourth Offers in
Compromise
On February 14, 1995, respondent received a second offer in
compromise from petitioners. On March 22, 1995, respondent
mailed a letter to petitioners informing them that their second
offer could not be processed.
On April 26, 1995, respondent received a third offer in
compromise from petitioners. On May 31, 1995, respondent mailed
a letter to petitioners informing them that their third offer
could not be processed.
On July 12, 1995, respondent received a fourth offer in
compromise from petitioners. On August 10, 1995, respondent
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