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See Woodral v. Commissioner, 112 T.C. 19, 23 (1999). Respondent
considered petitioner’s circumstances in light of the prescribed
guidelines for accepting offers. Respondent then reasonably
concluded that the information presented fell short of
establishing either the requisite economic hardship or other
exceptional factors demonstrating that compromise of the
liability will not undermine voluntary compliance with the tax
laws. The Court will sustain respondent’s collection action.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011