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neither argued nor demonstrated that his monthly income is
exhausted caring for them or that they have no other means of
support. Accordingly, petitioner has not shown that collection
of the full liability would cause him economic hardship.
2. Compelling Public Policy or Equity Considerations
Petitioner argues that his due process rights were violated
when respondent’s offer specialist asked him to provide a sworn
statement of his income from the paralegal business. According
to petitioner, the offer specialist requested the statement only
after informing him that she would reject his OIC because of the
real property interests he owned. Petitioner claims he asked the
offer specialist to make her request in writing, but she refused.
Petitioner contends that the offer specialist’s actions were
“arbitrary and capricious” and “denied * * * [him] due process”.
Although petitioner’s argument is vague, we interpret his
position to be that his OIC should have been accepted on the
basis of public policy or equity considerations.
The Secretary may enter into a compromise to promote
effective tax administration where compelling public policy or
equity considerations identified by the taxpayer provide a
sufficient basis for compromising the liability. Sec. 301.7122-
1(b)(3)(ii), Proced. & Admin. Regs. A compromise will be
justified only where, because of exceptional circumstances,
collection of the full liability would undermine public
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Last modified: May 25, 2011