- 18 - allowances”, referred to in section 7122(c)(2), and failed to determine, based upon the facts and circumstances of this case, whether it was appropriate to use those schedules. For his last reason, petitioner argues that “the financial information clearly showed that the IRS’ settlement demands would be an undue hardship on the taxpayer and his family, and basically force them into the streets.” In effect, petitioner is arguing that collection of the full liability for tax years 2000 and 2001 would cause petitioner and his family economic hardship within the meaning of section 301.6343-1, Proced. & Admin. Regs. Thus, it appears that petitioner is relying on section 301.7122-1(b)(3)(i), Proced. & Admin. Regs., to support his contention that respondent should have accepted his offer- in-compromise. Petitioner has identified no “compelling public policy or equity considerations”, applicable to his tax liability for taxable years 2000 and 2001, that would provide a basis to apply section 301.7122-1(b)(3)(ii), Proced. & Admin. Regs. We disagree with each of petitioner’s points and, for the reasons set out below, we find that the determination to proceed with collection of petitioner’s tax for 2000 and 2001 was not an abuse of respondent’s discretion.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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