- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011