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both counts. We do not believe that Cochran abused her
discretion by rejecting petitioners’ offer-in-compromise simply
because she may have established a due date for submission of
information. As a matter of fact, petitioners’ counsel by their
own admission acknowledge that Cochran had regularly granted
counsel’s repeated requests for extensions made in part because
counsel was mired from their acceptance of many of these cases
involving other partners of the Hoyt partnerships. Nor do we
believe that Cochran abused her discretion by rejecting
petitioners’ offer-in-compromise simply because she may not have
discussed with petitioners the contents of the notice of
determination (and given them a chance to dispute it) before
issuing the notice of determination to them. Cf. Fargo v.
Commissioner, 447 F.3d at 712-713 (holding that Appeals has no
duty to negotiate with a taxpayer before rejecting the taxpayer’s
offer-in-compromise). We also disagree with petitioners that
Cochran had an affirmative duty to attempt unilaterally to find
additional facts in support of their case as soon as she came to
the conclusion that their offer-in-compromise should be denied.
We hold that Appeals did not abuse its discretion in
rejecting petitioners’ $32,000 offer-in-compromise. In so
holding, we express no opinion as to the amount of any compromise
that petitioners could or should be required to pay, or that
respondent is required to accept. The only issue before us is
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