- 24 - 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 soPage: 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