- 9 - offer-in-compromise should be rejected for several reasons3 in addition to petitioner’s ability to pay. In arguing that the rejection of his offer-in-compromise was an abuse of discretion, petitioner also contends that Appeals Officer Wong failed to make a finding of net income for purposes of an installment agreement. Petitioner has not directed us to, and we are not aware of, any such requirement for purposes of rejecting an offer-in-compromise. Moreover, when Appeals Officer Wong presented to petitioner the opportunity to consider an installment agreement, petitioner declined to do so. Appeals Officer Wong’s rejection of petitioner’s offer-in-compromise was not an abuse of discretion. C. Conclusion We have considered the remaining arguments of both parties for results contrary to those discussed herein and, to the extent not discussed above, conclude those arguments are irrelevant, moot, or without merit.4 We shall sustain respondent’s 3In addition to determining that the amount of petitioner’s offer-in-compromise was inadequate, Appeals Officer Wong rejected petitioner’s offer-in-compromise because petitioner had a 17-year history of noncompliance with the Federal income tax laws; had not paid his 2000, 2001, or 2002 Federal income tax liability; and had not made required estimated tax payments as of the date of his hearing. See Londono v. Commissioner, T.C. Memo. 2003-99 (taxpayer’s history of noncompliance was basis for rejecting offer-in-compromise). 4In his posttrial memorandum of law, petitioner argued that he was denied due process when this Court granted respondent’s (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011