Donald and Yvonne Clayton - Page 20

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          we emphasize we do not make, we would not find that Cochran’s               
          rejection of petitioners’ offer was an abuse of discretion                  
          because we conclude below (in our discussion of petitioners’                
          fourth argument) that her acceptance of that offer would have               
          undermined voluntary compliance with tax laws by taxpayers in               
          general.  The prospect that acceptance of an offer will undermine           
          compliance with the tax laws militates against its acceptance.              
          See Rev. Proc. 2003-71, 2003-2 C.B. 517; IRM sec. 5.8.11.2.2; see           
          also Barnes v. Commissioner, T.C. Memo. 2006-150.                           
               Fourth, petitioners argue that public policy demands that              
          their offer-in-compromise be accepted because they were victims             
          of fraud.  We disagree.  While the regulations do not set forth a           
          specific standard for evaluating an offer-in-compromise based on            
          claims of public policy or equity, the regulations contain two              
          illustrative examples.  See sec. 301.7122-1(c)(3)(iv), Examples             
          (1) and (2), Proced. & Admin. Regs.  The first example describes            
          a taxpayer who is seriously ill and unable to file income tax               
          returns for several years.  The second example describes a                  
          taxpayer who received erroneous advice from the Commissioner as             
          to the tax effect of the taxpayer’s actions.  Neither example               
          bears any resemblance to this case.  See Speltz v. Commissioner,            
          454 F.3d at 786.  Unlike the exceptional circumstances                      
          exemplified in the regulations, petitioners’ situation is neither           
          unique nor exceptional in that petitioners’ situation mirrors               






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