Charles G. and Elizabeth A. Fargo - Page 5

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          see sec. 301.7122-1T(b)(4)(i), Temporary Proced. & Admin. Regs.,            
          supra; and, even if it did not, would because of “exceptional               
          circumstances” be “detrimental to voluntary compliance by                   
          taxpayers” by creating doubt as to the fair administration of the           
          tax laws, see sec. 301.7122-1T(4)(ii), Temporary Proced. & Admin.           
          Regs., supra.                                                               
               Respondent rejected both arguments.  He concluded that                 
          petitioners could fully satisfy both their tax debt and their               
          foreseeable expenses without economic hardship.  He also                    
          concluded that they had failed to show “exceptional                         
          circumstances” sufficient to justify accepting their compromise.            
               We examine each issue in turn, mindful that our review under           
          section 6330 is for abuse of discretion.  See Davis v.                      
          Commissioner, 115 T.C. 35, 39 (2000).  This standard does not ask           
          us to decide whether in our own opinion the offer in compromise             
          should have been accepted, but whether the Commissioner exercised           
          his “discretion arbitrarily, capriciously, or without sound basis           
          in fact or law.”  Woodral v. Commissioner, 112 T.C. 19, 23                  
          (1999).                                                                     
          A.   Hardship                                                               
               Petitioners suggest that although they currently enjoy                 
          fairly substantial means, their economic future is tainted by a             
          diagnosis that petitioner Charles Fargo suffers from a                      
          progressive neurological condition that may eventually require              






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