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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,
309, 320 n.10 (2005), affd. 469 F.3d 27 (1st Cir. 2006); Barnes
v. Commissioner, T.C. Memo. 2006-150.
A. Economic Hardship
Petitioners assert that Ms. Cochran abused her discretion by
rejecting their offer-in-compromise because “There is no
indication that SO Cochran gave any substantive consideration to
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