- 23 - 100 percent value. Petitioners offer no support for their use of an 80-percent quick-sale value. We find that Ms. Cochran’s use of 100 percent of the house’s value was not arbitrary or capricious. In one of the May 14, 2004, letters, petitioners listed a variety of problems with their house. However, petitioners did not provide any supporting documentation regarding the need for or the cost of repairs, but instead they invited Ms. Cochran to view the house in person. Petitioners believe that, despite the lack of supporting documentation, Ms. Cochran abused her discretion by not factoring in the cost of repairs. Petitioners assert that, if Ms. Cochran questioned petitioners’ representations, she could have requested more information or accepted petitioners’ invitation to view the house in person. Given the voluminous nature of the information provided to Ms. Cochran, we do not believe that she was under an obligation to request more information or to view the house in person. The burden was on petitioners to establish that they were entitled to an offer-in-compromise. Petitioners cannot shift this burden by simply inviting Ms. Cochran to request more information or to view the house in person. 4. Encouraging Voluntary Compliance With the Tax Laws We are also mindful that any decision by Ms. Cochran to accept petitioners’ offer-in-compromise due to doubt as toPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011