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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 for
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