- 22 -
petitioners compromise their $298,003 liability by paying less
than the amount of interest included within that liability.
We hold that Appeals did not abuse its discretion in
rejecting petitioners’ $83,213 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
whether Appeals abused its discretion in refusing to accept
petitioners' specific offer-in-compromise in the amount of
$83,213. See Speltz v. Commissioner, 124 T.C. at 179-180. We
have considered all arguments made by petitioners for a contrary
holding and have found those arguments not discussed herein to be
irrelevant and/or without merit.
An appropriate order will
be issued.
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Last modified: May 25, 2011