Keith and Cherie Orum - Page 20

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          As discussed with Mr. Orum at the section 6330 hearing, Ms.                 
          Vuicich found the information provided on petitioners’ Form 433A            
          to be incomplete and unverified.  We find that the Appeals                  
          officer could have reasonably rejected an installment agreement             
          proposal by petitioners on the basis of petitioners’ failure to             
          make the required monthly payments on the initial January 5,                
          2001, installment agreement that was terminated, and petitioners’           
          failure to timely provide the requested information to Ms.                  
          Vuicich in order for her to consider another installment                    
          agreement.                                                                  
               Additionally, respondent’s determination not to enter into             
          an offer-in-compromise agreement with petitioners was not an                
          abuse of discretion.  Section 7122(a) authorizes the Secretary to           
          compromise any civil case arising under the internal revenue                
          laws.  The regulations set forth three grounds for the compromise           
          of a liability:  (1) Doubt as to liability; (2) doubt as to                 
          collectibility; or (3) promotion of effective tax administration.           
          Sec. 301.7122-1T(b), Temporary Proced. & Admin. Regs., 64 Fed.              
          Reg. 39024 (July 21, 1999);4 see sec. 7122(c)(1).  Doubt as to              
          liability is not at issue in the instant case.                              
               The Secretary may compromise a liability on the ground of              
          doubt as to collectibility when “the taxpayer’s assets and income           


               4  Final regulations under sec. 7122 were promulgated                  
          effective for offers-in-compromise pending on or submitted on or            
          after July 18, 2002.  Sec. 301.7122-1(k), Proced. & Admin. Regs.            




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