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taxpayers in general. The prospect that acceptance of an offer
will undermine compliance with the tax laws militates against its
acceptance whether the offer is predicated on promotion of
effective tax administration or on doubt as to collectibility
with special circumstances. See Rev. Proc. 2003-71, 2003-2 C.B.
517; see also IRM sec. 5.8.11.2.2.
Fifth, petitioners argue that public policy demands that
their offer-in-compromise be accepted because they were victims
of fraud. We disagree. While the regulations do not set forth a
specific standard for evaluating an offer-in-compromise based on
claims of public policy or equity, the regulations contain two
illustrative examples. See sec. 301.7122-1(c)(3)(iv), Examples
(1) and (2), Proced. & Admin. Regs. The first example describes
a taxpayer who is seriously ill and unable to file income tax
returns for several years. The second example describes a
taxpayer who received erroneous advice from the Commissioner as
to the tax effect of the taxpayer’s actions. Neither example
bears any resemblance to this case. Accord Speltz v.
Commissioner, supra. Unlike the exceptional circumstances
exemplified in the regulations, petitioners’ situation is neither
unique nor exceptional in that their situation mirrors numerous
taxpayers who claimed tax shelter deductions in the 1980s and
1990s, obtained the tax advantages, promptly forgot about their
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