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F.3d 706 (9th Cir. 2006), as counsel for the amici. While
petitioners in their brief suggest that the Court of Appeals for
the Ninth Circuit knowingly wrote its opinion in Fargo in such a
way as to distinguish that case from the cases of counsel’s
similarly situated clients (e.g., petitioners), and otherwise to
allow those clients to receive an abatement of their liability
attributable to partnerships such as those here, we do not read
the opinion of the Court of Appeals for the Ninth Circuit in
Fargo to support that conclusion.
Third, petitioners argue that Cochran inadequately
considered their unique facts and circumstances. We disagree.
Cochran reviewed and considered all information given to her by
petitioners. On the basis of the facts and circumstances of
petitioners’ case as they had been presented to her, Cochran
determined that petitioners’ offer did not meet the applicable
guidelines for acceptance of an offer-in-compromise due to doubt
as to collectibility with special circumstances or to promote
effective tax administration. We find no abuse of discretion in
that determination.
Petitioners take exception to the fact that the notice of
determination does not state specifically that petitioners are in
their sixties and retired, speculating from this fact that
Cochran did not adequately take into account their special
circumstances. Petitioners also assert that Cochran failed to
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