- 9 - taxpayers with the tax laws.10 Sec. 301.7122-1(b)(3), Proced. & Admin. Regs. Petitioner proposed an offer-in-compromise based on effective tax administration, arguing that exceptional circumstances existed such that collection of the full liability would undermine public confidence that the tax laws are being administered in a fair and equitable manner. Respondent determined that petitioner’s offer-in-compromise did not meet the criteria for an effective tax administration offer-in-compromise. Because the underlying tax liability is not at issue, our review under section 6330 is for abuse of discretion. See Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 182 (2000). This standard does not ask us to decide whether in our own opinion petitioner’s offer-in- compromise should have been accepted, but whether respondent’s rejection of the offer-in-compromise was arbitrary, capricious, or without sound basis in fact or law. Woodral v. Commissioner, 112 T.C. 19, 23 (1999); Keller v. Commissioner, T.C. Memo. 2006- 166; Fowler v. Commissioner, T.C. Memo. 2004-163. 10 The regulations also provide that the Secretary may compromise a liability on the ground of effective tax administration when collection of the full liability will create economic hardship. See sec. 301.7122-1(b), Proced. & Admin. Regs. While petitioner disputes Ms. Cochran’s determination of his reasonable collection potential, he does not argue that collection of the full liability would create economic hardship.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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