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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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Last modified: May 25, 2011