Roger and Lora Carter - Page 23

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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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