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with the decision being that the taxpayers have
conceded the interest abatement issue for the years
1981, 1982, 1983, 1984, 1985, and 1986.
With respect to the taxpayers’ second area of concern,
the Settlement Officer has evaluated the taxpayers’
$32,000 offer to compromise the underlying liabilities
as a collection alternative to the proposed levy
action. Based on that evaluation, the taxpayers’ offer
of $32,000 could not be recommended for acceptance, and
therefore cannot be considered as a collection
alternative.
In all other respects, the proposed levy action
regarding the taxpayers represents the only efficient
means for collection of the liability at issue in this
case.
The notice states that petitioners have neither offered an
argument nor cited any authority to permit Appeals to deviate
from the provisions of the IRM.
As to petitioners’ claim at the hearing for an interest
abatement, Cochran ascertained that petitioners had filed the
case in this Court seeking an abatement of interest upon section
6404(e) for the same years at issue here. She also ascertained
that the parties to that case had on February 9, 2005, filed with
this Court a stipulated decision through which petitioners
conceded that they were not entitled to their requested interest
abatement. Cochran determined that petitioners were not entitled
in this case to their claim for an abatement of interest, either
under section 6404(e) or as part of an offer-in-compromise.
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Last modified: May 25, 2011