- 23 - otherwise be acceptable under the Secretary’s policies and procedures”, sec. 301.7122-1(c)(1), Proced. & Admin. Regs., we find to the contrary. Cochran thoroughly considered petitioners’ arguments for accepting their offer-in-compromise, and she rejected the offer only after concluding that petitioners could pay more of their tax liability than the $100,000 they offered. Cf. IRM sec. 5.8.11.2.1.11 (“When hardship criteria are identified but the taxpayer does not offer an acceptable amount, the offer should not be recommended for acceptance”). Sixth, petitioners argue that Cochran inappropriately failed to consider whether they qualified for an abatement of interest for reasons other than those described in section 6404(e). We disagree. While Cochran declined to accept petitioners’ request to reject the proposed levy because their interest abatement case had been resolved, we find nothing to suggest that Cochran believed that petitioners’ sole remedy for interest abatement in this case rested on the rules of section 6404(e). In fact, regardless of the rules of section 6404(e) and the stipulated decision, Cochran obviously would have abated interest in this case had she agreed to let petitioners compromise their approximately $275,000 liability by paying less than the amount of interest included within that liability. Seventh, petitioners argue that Cochran erred in not allowing their counsel additional time to submit documents forPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011