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offer-in-compromise, and she rejected the offer only after
concluding that petitioners could pay more of their tax liability
than the $32,000 they offered. Cf. IRM sec. 5.8.11.2.1.11 (“When
[economic] hardship criteria are identified but the taxpayer does
not offer an acceptable amount, the offer should not be
recommended for acceptance”).
Seventh, petitioners argue that Cochran inappropriately
failed to consider whether they qualified for an abatement of
interest for reasons other than those described in section
6404(e). We disagree. While Cochran declined to accept
petitioners’ request to reject the proposed levy because of their
interest abatement case, given that the interest abatement case
had been resolved, we find nothing to suggest that Cochran
believed that petitioners’ sole remedy for interest abatement in
this case rested on the rules of section 6404(e). In fact,
regardless of the rules of section 6404(e) and the stipulated
decision, Cochran obviously would have abated interest in this
case had she agreed to let petitioners compromise their
approximately $400,000 liability by paying less than the amount
of interest included within that liability.
Eighth, petitioners argue that Cochran erred in not allowing
their counsel additional time to submit documents for Cochran’s
consideration and by not informing petitioners of the contents of
the notice of determination before it was issued. We disagree on
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