Barry and Sherry Blondheim - Page 15

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          supra, 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 to promote              
          effective tax administration based on economic hardship or public           
          policy or equity grounds.  We find no abuse of discretion in that           
          determination.  Nor do we find that Cochran inadequately                    
          considered the information actually given to her by petitioners.            
          Cochran allowed the full amount of medical expenses that                    
          petitioners submitted on their Form 433-A.  While petitioners               
          claimed during the administrative hearing that they would incur             
          increased medical expenses in the future, they provided no                  






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