Charles G. and Elizabeth A. Fargo - Page 4

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          final notice of intent to levy.  Petitioners timely requested a             
          hearing, the focus of which was their offer to compromise the               
          nearly two decades of compound interest for $7,500.  The Appeals            
          officer rejected their offer and determined that a levy was                 
          appropriate.  This action followed.  The case was calendared for            
          trial in California, where the Fargos resided when they filed               
          their petition.  The parties stipulated the relevant facts, and             
          moved to submit the case for decision without trial under Rule              
          122.                                                                        
                                     Discussion                                       
               Section 7122(c) directs the Secretary to prescribe                     
          guidelines for determining whether to accept or reject specific             
          offers in compromise.  Under section 301.7122-1T(b), Temporary              
          Proced. & Admin. Regs., 64 Fed. Reg. 39024 (July 21, 1999),2                
          there are three grounds for compromise:  Doubt as to liability,             
          doubt as to collectibility, and promotion of effective tax                  
          administration.  Petitioners argue that their compromise offer              
          met two of the temporary regulations’ separate standards for                
          acceptance “in furtherance of effective tax administration”--               
          collection of the full amount would cause them economic hardship,           


               2 As petitioners submitted their offer in compromise after             
          July 21, 1999, and before July 18, 2002, it is governed by the              
          temporary regulations that were then in force.  (The portions               
          relevant to this case survived in substantially similar form in             
          the final regulations at sec. 301.7122-1(b), Proced. & Admin.               
          Regs.)                                                                      





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