Sal and Ruth Alaniz - Page 7

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          applicable law and administrative procedures have been met, and             
          consider “whether any proposed collection action balances the               
          need for the efficient collection of taxes with the legitimate              
          concern of the person [involved] that any collection action be no           
          more intrusive than necessary.”  Sec. 6330(c)(3)(C).   Here,                
          petitioners do not dispute that all administrative procedures               
          have been met so the sole issue for our consideration is whether            
          respondent’s rejection of petitioners’ OIC was an abuse of                  
          discretion.                                                                 
               Section 7122 provides respondent with the authority to grant           
          an offer in compromise as an alternative to collection action.              
          Respondent grants an offer in compromise when there is a doubt as           
          to the actual tax liability, doubt as to collectibility, or for             
          other purposes relating to effective tax administration.  Sec.              
          301.7122-1, Proced. & Admin. Regs.; 1 Administration, Internal              
          Revenue Manual (CCH), sec. 5.8.1.1.2, at 16,253.                            
               The Appeals officer considered petitioners’ $2,000 offer on            
          the grounds of “doubt as to collectibility” (as such term is used           
          in the context of the foregoing reference to the regulations and            
          the Internal Revenue Manual).  The Appeals officer also took into           
          consideration as a potential ground for compromise the promotion            
          of effective tax administration.  See sec. 301.7122-1(b)(3),                
          Proced. & Admin. Regs.  Respondent may accept an offer in                   
          compromise based on doubt as to collectibility when there are               






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