- 24 - 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); WelchPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011