William C. Eberhardt, Jr. and Susan A. Eberhardt - Page 16

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               When there are no grounds for compromise under the                     
          provisions pertaining to doubt as to liability, doubt as to                 
          collectibility, or effective tax administration due to economic             
          hardship, the IRS may compromise a liability to promote effective           
          tax administration where compelling public policy or equity                 
          considerations identified by the taxpayer provide a sufficient              
          basis for compromising the liability.  Sec. 301.7122-1(b)(3)(ii),           
          Proced. & Admin. Regs.  Compromise will be justified only where,            
          due to exceptional circumstances, collection of the full                    
          liability would undermine public confidence that the laws are               
          being administered in a fair and equitable manner.  A taxpayer              
          proposing such a compromise will be expected to demonstrate                 
          circumstances that justify compromise even though a similarly               
          situated taxpayer may have paid his liability in full.  Id.                 
               Petitioners have failed to demonstrate that there are any              
          circumstances showing that collection of their full liability               
          would undermine public confidence that the tax laws are being               
          administered fairly and equitably.  Petitioners have not shown              
          evidence sufficient to warrant consideration of an OIC based on             
          effective tax administration grounds.                                       
               Having reviewed the entire record, including the financial             
          information presented to Ms. Clinger, the Court cannot find that            
          the determination rejecting petitioners' OIC was an abuse of                
          discretion.  See Van Vlaenderen v. Commissioner, T.C. Memo.                 






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