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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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