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$255,254. Petitioners argued that collection of the full
liability would create economic hardship and would undermine
public confidence that the tax laws are being administered in a
fair and equitable manner. Respondent determined that
petitioners’ reasonable collection potential was $380,076 and
that their offer-in-compromise did not meet the criteria for an
offer-in-compromise based on either doubt as to collectibility
with special circumstances or effective tax administration.
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 petitioners’ 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. Because the
same factors are taken into account in evaluating offers-in-
compromise based on doubt as to collectibility with special
circumstances and on effective tax administration (economic
hardship or considerations of public policy or equity), we
consider petitioners’ separate grounds for their offer-in-
compromise together. See Murphy v. Commissioner, 125 T.C. 301,
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