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On his Form 433-A, petitioner reported the estimated fair
market value of his Arizona property at 1015 Fair Street
Prescott, AZ 86305, as $87,000, with an 80-percent quick-sale
value of $69,600 and an outstanding encumbrance of zero.
Petitioner’s estimate was based upon the Yavapai County, Arizona,
Assessor’s Office appraisal dated January 31, 2003. Ms. Cochran
discovered petitioner had given her the Yavapai County Assessor’s
address, not the property’s actual location. The Arizona
property was at 2320 West Live Oak Drive, Prescott, AZ. Ms.
Cochran did not accept petitioner’s reported value. Instead, she
determined the property’s value at $150,000 using recent
comparable sales.
Assuming petitioner’s professional appraisal and assessor
valuation should have been accepted, this Court would not find
Ms. Cochran abused her discretion in rejecting petitioner’s
offer-in-compromise based on economic hardship. On his Form 433-
A, petitioner reported assets with a total value of $232,436 and
income potential of approximately $151,872. However, petitioner
offered to pay only $102,000 to compromise his outstanding tax
liabilities. This Court finds Ms. Cochran did not abuse her
discretion by rejecting an offer-in-compromise that bore no
relationship to petitioner’s own calculations of his ability to
pay.
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