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holding, we express no opinion as to the amount of any compromise
that petitioners could or should be required to pay, or that
respondent is required to accept. The only issue before us is
whether Appeals abused its discretion in refusing to accept
petitioners' specific offer-in-compromise in the amount of
$100,000. See Speltz v. Commissioner, 124 T.C. at 179-180. We
have considered all arguments made by petitioners for a contrary
holding and have found those arguments not discussed herein to be
without merit.
An appropriate order will
be issued.
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