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The taxpayers’ circumstances were considered, but the
taxpayers would have substantial assets and income
stream remaining ($630,000+) to cover their living and
medical expenses. As such, the taxpayers failed to
document economic hardship in accordance with Internal
Revenue Manual 5.8.11.2.1.
As to petitioners’ offer-in-compromise to promote effective tax
administration based on equity and public policy, the notice
states: “When considered under public policy or equity grounds,
the taxpayers’ Effective Tax Administration offer proposal fails
to meet the criteria for such consideration under Internal
Revenue Manual 5.8.11.2.2 * * * [and], therefore, cannot be
considered.” The notice further states as to Cochran’s balancing
of efficient collection with the legitimate concerns of taxpayers
that
the Settlement Officer has evaluated the taxpayers’
$83,213 offer to compromise the underlying liabilities
as a collection alternative to the proposed levy
action. Based on that evaluation, the taxpayers’ offer
of $83,213 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 liabilities 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.
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Last modified: May 25, 2011