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petitioner had not demonstrated undue hardship as defined
by section 301.6343-1(b)(4)(i), Proced. & Admin. Regs.
At that conference, the Appeals officer suggested that
petitioner consider “an installment agreement and/or
liquidation of your retirement accounts in order to
satisfy the tax liability.” The Appeals officer also sent
petitioner and his attorney a letter setting forth certain
conditions, such as full payment for petitioner’s 2003
tax liability, to continue consideration of collection
alternatives. Our review of the record fails to show any
basis for the assertion that the Appeals officer “summarily
rejected” petitioner’s offer-in-compromise.
Finally, we do not agree with petitioner’s assertion
that collection of the full tax liability for taxable years
2000 and 2001 would cause petitioner and his family
economic hardship within the meaning of section 301.6343-1,
Proced. & Admin. Regs. The financial information
petitioner submitted with his offer-in-compromise
demonstrates that petitioner had a robust earning capacity
through his stock brokerage business. The Form 433-A
submitted with petitioner’s offer-in-compromise suggests
that his income exceeded living expenses by $9,428 per
month before income taxes. Certainly, monthly income in
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