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& Admin. Regs. Doubt as to liability and doubt as to
collectibility11 are not at issue in this case.
Petitioner proposed an offer-in-compromise based on ETA,
offering to pay $102,000 to compromise his estimated outstanding
tax liability of $230,000. Petitioner argued that collection of
the full liability would create economic hardship and that
compelling public policy or equity considerations provide a
sufficient basis for compromising the liability. Respondent
determined petitioner’s reasonable collection potential was
$663,914, and thus, petitioner’s offer did not meet the criteria
for an offer-in-compromise based on ETA.
A tax liability may be compromised on the ground of ETA
when: (1) Collection of the full liability will create economic
hardship; or (2) compelling public policy or equity
considerations provide a sufficient basis for compromising the
liability; and (3) compromise of the liability would not
undermine compliance by taxpayers with the tax laws. Sec.
301.7122-1(b)(3), Proced. & Admin. Regs.
11 Petitioner alleged respondent erred by not finding there
was doubt as to collectibility. However, petitioner did not
present information to substantiate this claim and did not argue
it on brief. This Court concludes petitioner has abandoned this
argument.
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