- 9 -
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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