Gary W. McDonough - Page 18

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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              

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