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includes only 80 percent of the value of petitioners’ house,
discussed in more detail below, and does not include the value of
any future pension payments.
Respondent may accept an offer-in-compromise based on doubt
as to collectibility with special circumstances or on effective
tax administration even if the offer amount is less than
petitioners’ reasonable collection potential. However, given all
other considerations discussed herein, we do not believe that Ms.
Cochran abused her discretion by rejecting an offer-in-compromise
that bore no relationship to petitioners’ ability to pay based on
their own calculations.
3. The Value of Petitioners’ House
Petitioners argue that Ms. Cochran improperly valued their
house. Petitioners also argue that Ms. Cochran failed to take
into consideration the need for repairs. Petitioners’ arguments
are not persuasive.
On their Form 433-A, petitioner reported that their house
had an estimated 80-percent quick-sale value of $220,200. Ms.
Cochran increased the house’s value to reflect its 100-percent
value, $275,250. Petitioners argue that, if there was a dispute
over value, Ms. Cochran should have hired a professional
valuation expert. Petitioners argument is without merit because
there was no dispute over value. Ms. Cochran accepted the value
reported by petitioners, only adjusting it to reflect the house’s
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