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expenses. Petitioners made an estimate of $3,000 for the value
of their primary car and the Appeals officer used this figure to
calculate the quick sale value of $2,400. Based on this premise,
the Appeals officer determined that an offer of $2,400 would be
an appropriate amount to settle the outstanding liabilities due
for 1990-92 and 1994-96. The Appeals officer requested a lump-
sum payment through the sale of petitioners’ primary vehicle.
Petitioners rejected this approach as this was their primary
vehicle and to sell it would have caused great financial harm.
Petitioners submitted an amended offer in compromise for
$2,400, to be paid in $100 monthly installments. Under those
terms, the $2,400 compromise could be paid in full in 2 years.
That offer was rejected due to the Appeals officer’s
determination that petitioners were financially unable to make
the payments. We note that petitioners had cooperated with all
requests from the Internal Revenue Service in an attempt to
resolve this matter.
Appeals officers, in the consideration of an offer in
compromise should verify that the requirements of applicable law
and administrative procedures have been met, and “whether any
proposed collection action balances the need for the efficient
collection of taxes with the legitimate concern of the person
that any collection action be no more intrusive than necessary.”
See sec. 6330(c)(3)(C). The verification of applicable law and
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