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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...)
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Last modified: May 25, 2011