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confidence that the tax laws are being administered in a fair and
equitable manner. A taxpayer proposing a compromise on the basis
of effective tax administration will be expected to demonstrate
circumstances that justify a compromise even though a similarly
situated taxpayer may have paid his liability in full. Id.
Examples of where a compromise is allowed for purposes of public
policy and equity include: (1) A taxpayer who was hospitalized
regularly for a number of years and was unable to manage his
financial affairs incurs significant tax liabilities, penalties
and interest; and (2) a taxpayer learns at audit that he received
erroneous advice from the IRS and, as a result, is facing
additional taxes, penalties, and additions to tax. Speltz v.
Commissioner, supra at 173; sec. 301.7122-1(c)(3)(C)(iv), Proced.
& Admin. Regs.
Petitioner has identified no public policy or equity
considerations that would justify a compromise on the basis of
effective tax administration. The Government may request
additional information from a taxpayer after an OIC is accepted
for processing. Sec. 301.7122-1(d)(2), Proced. & Admin. Regs.
The taxpayer’s refusal to provide the requested information
within a reasonable time is grounds for returning the OIC. Id.
Petitioner failed to mention the paralegal business in his OIC.
When the offer specialist learned of the existence of this
business, she was entitled to request additional information,
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