- 17 - offer was returned to petitioners as not processable in the form submitted. A second offer (we assume corrected) was sent to the IRS the day after the notices of determination were sent. Since there was no offer in compromise before Appeals, there was no abuse of discretion in Appeals’ failing to consider an offer in compromise. Finally, petitioners can raise no issue here that they did not raise during their collection due process hearing. See Magana v. Commissioner, 118 T.C. 488, 493 (2002); secs. 301.6320-1(f)(2), Q&A-F5, and 301.6330-1(f)(2), Q&A-F5, Proced. & Admin. Regs. D. Conclusion Petitioners have failed to show any error in Appeals’ determination to proceed to collect by levy the unpaid assessments. IV. Conclusion As stated, we shall grant the motion. An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011