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Asset Equity
Checking account $739
Individual retirement 17,937
account
Annuity 104,135
1987 Honda Accord 340
Dissipated asset 10,000
Total 133,151
3. Summary
Petitioners’ reasonable collection potential is $175,535.
Because their reasonable collection potential is greater than
their offer amount, we find that Mr. Owens’s rejection of
petitioners’ offer-in-compromise based on doubt as to
collectibility was not arbitrary or capricious.
C. Petitioners’ Other Arguments
1. Information Sufficient for the Court To Review
Respondent’s Determination
Petitioners argue that respondent failed to provide the
Court with sufficient information “so that this Court can conduct
a thorough, probing, and in-depth review of respondent’s
determinations.” Petitioners’ argument is without merit.
Generally, a taxpayer bears the burden of proving the
Commissioner’s determinations incorrect. Rule 142(a)(1); Welch
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