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offer was grounded on effective tax administration was based on
her conclusion that respondent could not collect the full 1992-
2001 liability from petitioner (the potential of collection in
full being a prerequisite to any consideration of special
circumstances, such as hardship or equity, justifying an offer in
compromise grounded on effective tax administration). We also
think that petitioner’s testimony is not relevant to the question
of whether Ms. Boudreau abused her discretion in rejecting the
offer to the extent the offer was grounded on doubt as to
collectibility. The 1992-2001 liability ($275,777) exceeds both
the amount Ms. Boudreau determined to be the reasonable
collection potential of the case ($82,164) and the amount
petitioner offered ($10,000). Because the offer was in an amount
less than what she determined to be the reasonable collection
potential, Ms. Boudreau could not consider the offer unless there
were special circumstances. Nevertheless, petitioner did not
timely provide her with all of the evidence that he now believes
should be taken into account in determining whether there are
special circumstances. An appeals officer does not abuse her
discretion when she fails to take into account information that
she requested and that was not provided in a reasonable time. As
explained in the next paragraph, that is the case here with
respect to petitioner’s trial testimony. Here, evidence that
petitioner might have presented at the section 6330 hearing (but
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