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public confidence that the tax laws are being administered in a
fair and equitable manner; and (2) compromise will not undermine
compliance by taxpayers with the tax laws. Sec. 301.7122-
1(b)(3), Proced. & Admin. Regs.
To enable the Commissioner to evaluate a taxpayer’s
qualification for an offer in compromise, and particularly in the
face of allegations of economic hardship, the taxpayer must
submit complete financial data. Petitioner, however, has
admitted that he never supplied a completed Form 656 or 433-A to
respondent. Hence, although the Court is sympathetic to the
economic difficulties brought on by petitioner’s marital
separation and medical condition, it cannot be said that
respondent acted arbitrarily or capriciously in determining to
leave in place the filed lien when petitioner submitted no offer
in compromise or documentation of his financial circumstances.
Petitioner at trial communicated an interest in pursuing an
offer in compromise on a prospective basis, and the Court would
encourage these efforts. Nonetheless, as of the January 10,
2002, date of the notice of determination, the record does not
reveal any abuse of discretion on the part of respondent. We
shall sustain respondent’s collection efforts in the form of a
filed Federal tax lien.
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Last modified: May 25, 2011