Edward F. Murphy - Page 16

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          administered in a fair and equitable manner.  Sec. 301.7122-                
          1(b)(3)(ii), Proced. & Admin. Regs.                                         
               Where, because the reasonable collection potential of the              
          case exceeds the taxpayer’s liability, doubt as to collectibility           
          is not a ground for compromise, the Secretary may enter into a              
          compromise on the ground of effective tax administration.  Sec.             
          301.7122-1(b)(3), Proced. & Admin. Regs.  Before the Secretary              
          will enter into a compromise on the ground of effective tax                 
          administration, the taxpayer must show, among other things, that            
          collection in full would cause him economic hardship or, if he              
          cannot, that compelling public policy or equity considerations              
          justify such compromise.  Id.                                               
          IV.  The Parties’ Arguments                                                 
               In support of his assignment of error, petitioner avers that           
          (1) acceptance of an offer in compromise was in the best                    
          interests of respondent and petitioner, and (2) Ms. Boudreau                
          improperly and prematurely concluded the section 6330 hearing.              
          With respect to the averments, petitioner asks us to consider not           
          only the administrative record of the hearing, which consists of            
          documents stipulated by the parties (the hearing record), but               
          also petitioner’s and Ms. Boudreau’s trial testimony.                       
               Respondent answers that Ms. Boudreau did not abuse her                 
          discretion in rejecting the offer in compromise and determining             
          that respondent may proceed to collect the unpaid tax by levy,              






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