Gary W. McDonough - Page 12

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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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