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date. As a result, the Settlement Officer considered
the taxpayers’ request for interest abatement within
the present hearing.
With respect to the taxpayers’ second area of concern,
the Settlement Officer has evaluated the taxpayers’
$35,000 offer to compromise the underlying liabilities
as a collection alternative to the proposed levy
action. Based on that evaluation, the taxpayers’ offer
of $35,000 could not be recommended for acceptance, and
therefore cannot be considered as a collection
alternative. The taxpayers requested no other
collection alternative to be considered.
In all other respects, therefore, the proposed levy
action regarding the taxpayers represents the only
efficient means for collection of the liability at
issue in this case.
The notice states that petitioners have neither offered an
argument nor cited any authority to permit Appeals to deviate
from the provisions of the IRM.
As to petitioners’ claim at the hearing for an interest
abatement, Cochran ascertained that petitioners had previously
filed a request for interest abatement with respondent but that
the request had not yet been acted upon. She therefore
considered the interest abatement request as part of petitioners’
hearing. Cochran ultimately determined that petitioners were not
entitled to their claim for an abatement of interest, either
under section 6404(e) or as part of an offer-in-compromise.
OPINION
This case is yet another in a long list of cases brought in
this Court involving respondent’s proposal to levy on the assets
of a partner in a Hoyt partnership to collect Federal income
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Last modified: May 25, 2011