James J. Crisan and Veronica L. Crisan - Page 9

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          on doubt as to liability or doubt as to collectibility, and                 
          taxpayer has exceptional circumstances to merit the offer).                 
               Petitioners argue that they lack sufficient assets to                  
          satisfy the tax liabilities.  The Appeals officer reviewed                  
          petitioners’ submitted financial information at the hearing and             
          determined that an offer in compromise was not appropriate.  We             
          received as exhibits the financial information presented to the             
          Appeals officer and find that the Appeals officer could have                
          reasonably concluded that there are sufficient income and assets            
          to satisfy the tax liabilities.  On the basis of respondent’s               
          consideration of petitioners’ information, we conclude that                 
          respondent’s refusal to enter into an offer in compromise was not           
          an abuse of discretion.                                                     
               As a result, we hold that the issuance of the notice of                
          determination was not an abuse of respondent’s discretion, and              
          respondent may proceed with collection.                                     
               In reaching our holding herein, we have considered all                 
          arguments made, and, to the extent not mentioned above, we                  
          conclude that they are moot, irrelevant, or without merit.                  
               To reflect the foregoing,                                              
                                                       Decision will be               
                                                  entered for respondent.             









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