- 12 - & 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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