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discretion in the Appeals officer’s determination to reject
petitioners’ de minimis offer in compromise. The Government is
entitled to preserve its priority regarding petitioners’ assets,
given their value and the uncertainty regarding their
disposition. In the face of petitioners’ de minimis offer,
respondent’s willingness to forgo collection until petitioners’
financial situation changes was reasonable and certainly was not
an abuse of discretion.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011