- 13 - Rejection of Petitioners’ OIC Because petitioners cannot dispute their underlying tax liability, we review respondent’s determination with respect to their OIC under the abuse of discretion standard. See sec. 6330(d); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000). We find that respondent’s rejection of petitioners’ proposed OIC was not an abuse of discretion. Respondent’s determination was based on all of the information petitioners provided reflecting their financial solvency to Ms. Roberts, respondent’s Appeals Officer. See Crisan v. Commissioner, T.C. Memo. 2003- 318; Schulman v. Commissioner, T.C. Memo. 2002-129. The Appeals officer reasonably determined, on the basis of petitioners’ yearly income ($35,616) and asset value (TD Waterhouse account, $41,301.41; vehicles--including “1995 boat”, $59,100; and Mrs. Caple’s profit sharing plan, $30,000)--totaling $166,017.41--that petitioners’ proposed OIC to pay $100 should be rejected. In addition to the $100 payment, petitioners also offered “$180,000 in future benefits” as part of their OIC. Unsure of exactly what petitioners meant by this offer, the Court attempted to ascertain petitioners’ intent. The Court’s query on this matter resulted in the following exchange: THE COURT: These are for future credits, not past credits? MS. CAPLE: Future credits. THE COURT: Future credits?Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: March 27, 2008