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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 to
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