Donald and Yvonne Clayton - Page 23

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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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