Kenneth Hawkins - Page 9

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          not at issue, the Court will review the Commissioner’s                      
          administrative determination for an abuse of discretion.  Id.;              
          Goza v. Commissioner, supra at 181-182.  Petitioner does not                
          dispute the validity of the underlying tax.  Accordingly, our               
          review is for an abuse of discretion.                                       
               We do not conduct an independent review of what would be               
          acceptable offers-in-compromise.  We review only whether the                
          Appeals officer’s rejection of the offer-in-compromise was                  
          arbitrary, capricious, or without sound basis in fact or law.               
          Woodral v. Commissioner, 112 T.C. 19, 23 (1999).  The Court                 
          considers whether the Commissioner abused his discretion in                 
          rejecting a taxpayer’s position with respect to any relevant                
          issues, including offers of collection alternatives, which                  
          include an offer-in-compromise.  See sec. 6330(c)(2)(A).                    
               Section 7122(a) authorizes the Secretary to compromise any             
          civil case arising under the internal revenue laws.  The three              
          standards that the Secretary may use to compromise a liability              
          are doubt as to liability, doubt as to collectibility, and the              
          promotion of effective tax administration.  Sec. 7122(c)(1); sec.           
          301.7122-1T(b), Temporary Proced. & Admin. Regs., 64 Fed. Reg.              
          39024 (July 19, 1999).8  Petitioner bases both offers on doubt as           


               8 Sec. 7122(c) is effective only for offers-in-compromise              
          submitted after July 22, 1998.  Internal Revenue Service                    
          Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3462,           
          112 Stat. 764.  Sec. 301.7122-1T(b), Temporary Proced. & Admin.             
          Regs., 64 Fed. Reg. 39024 (July 19, 1999), is effective for                 
          offers submitted after July 19, 1999, but sec. 301.7122-1,                  




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