- 20 - 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011