Edie D. Glass - Page 6

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          v. Commissioner, 114 T.C. 176, 183 (2000).  In so doing, we do              
          not conduct an independent review of what would be an acceptable            
          offer in compromise.  Van Vlaenderen v. Commissioner, T.C. Memo.            
          2003-346.  We review only whether the Appeals officer’s refusal             
          to accept the offer in compromise made by petitioner was                    
          arbitrary, capricious, or without sound basis in fact or law.               
          See Woodral v. Commissioner, 112 T.C. 19, 23 (1999).                        
               Under section 6330, a taxpayer is entitled to one hearing in           
          which he or she may raise any relevant issue relating to the                
          unpaid tax or the proposed levy, including offers of collection             
          alternatives such as an offer in compromise.  Sec. 6330(b) and              
          (c)(2).  In the present case, petitioner contends that respondent           
          should not have rejected her offer in compromise.  The Appeals              
          officer’s determination was based on an analysis of the                     
          information that petitioner submitted.  On the basis of the                 
          information considered by the Appeals officer, we cannot conclude           
          that rejection of petitioner’s offer in compromise was an abuse             
          of discretion.  See Van Vlaenderen v. Commissioner, supra; Crisan           
          v. Commissioner, T.C. Memo. 2003-318; Willis v. Commissioner,               
          T.C. Memo. 2003-302; O’Brien v. Commissioner, T.C. Memo. 2003-              
          290; Schulman v. Commissioner, T.C. Memo. 2002-129.  Petitioner’s           
          offer in compromise of $2,496 was based upon total “gross”                  
          monthly income of $2,600 and “Other expenses” of $300 per month             
          for a watchdog.  In determining the minimum acceptable offer of             

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