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her consideration and by not informing petitioners of the
contents of the notice of determination before it was issued. We
disagree on both counts. We do not believe that Cochran abused
her discretion by rejecting petitioners’ offer-in-compromise
simply because she may have established a due date for submission
of information. See Barnes v. Commissioner, T.C. Memo. 2006-150.
By their own admission, petitioners’ counsel failed to meet many
of Cochran’s deadlines (before Cochran extended them) because
petitioners’ counsel was pressed by other business from their
acceptance of many cases involving other partners of the Hoyt
partnerships. Nor do we believe that Cochran abused her
discretion by rejecting petitioners’ offer-in-compromise simply
because she may not have discussed with petitioners the contents
of the notice of determination (and given them a chance to
dispute it) before issuing the notice of determination to them.
Id.; cf. Fargo v. Commissioner, 447 F.3d at 712-713 (holding that
Appeals has no duty to negotiate with a taxpayer before rejecting
the taxpayer’s offer-in-compromise). In this regard, we also
disagree with petitioners that Cochran had an affirmative duty to
attempt unilaterally to find additional facts in support of their
case as soon as she came to the conclusion that their offer-in-
compromise should be denied. See Barnes v. Commissioner, supra.
We hold that Appeals did not abuse its discretion in
rejecting petitioners’ $100,000 offer-in-compromise. In so
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