- 11 -
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.
As to petitioners’ claim at the hearing for an interest
abatement, Cochran ascertained that petitioners had filed the
case in this Court seeking an abatement of interest under section
6404(e) for the same years at issue here. She also learned that
the parties to that case had on February 7, 2005, filed with this
Court a stipulated decision through which petitioners conceded
they were not entitled to their requested interest abatement.
Cochran determined that petitioners were not entitled in this
case to their claim for an abatement of interest, either under
section 6404(e) or as part of an offer-in-compromise.
OPINION
This case is another in a long list of cases brought in this
Court involving respondent’s proposal to levy on the assets of a
partner in a Hoyt partnership to collect Federal income taxes
attributable to the partner’s participation in the partnership.
Petitioners argue that Appeals was required to let them pay
$100,000 to compromise what they estimate is their approximately
$275,000 Federal income tax liability for 1982 through 1996.
Where an underlying tax liability is not at issue in a case
invoking our jurisdiction under section 6330(d), we review the
determination of Appeals for abuse of discretion. See Sego v.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011