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taxes attributable to the partner’s participation in the
partnership. Petitioners argue that Appeals was required to let
them pay $35,000 to compromise what they estimate is their
approximately $575,000 Federal income tax liability for 1981
through 1998. Where an underlying tax liability is not at issue
in a case invoking our jurisdiction under section 6330(d), we
review the determination of Appeals for abuse of discretion. See
Sego v. Commissioner, 114 T.C. 604, 610 (2000); see also Clayton
v. Commissioner, T.C. Memo. 2006-188; Barnes v. Commissioner,
T.C. Memo. 2006-150. We reject the determination of Appeals only
if the determination was arbitrary, capricious, or without sound
basis in fact or law. See Cox v. Commissioner, 126 T.C. 237, 255
(2006); Murphy v. Commissioner, 125 T.C. 301, 308, 320 (2005),
affd. 469 F.3d 27 (1st Cir. 2006).
Where, as here, we decide the propriety of Appeals’s
rejection of an offer-in-compromise, we review the reasoning
underlying that rejection to decide whether the rejection was
arbitrary, capricious, or without sound basis in fact or law.
We do not substitute our judgment for that of Appeals, and we do
not decide independently the amount that we believe would be an
acceptable offer-in-compromise. See Murphy v. Commissioner,
supra at 320; see also Clayton v. Commissioner, supra; Barnes v.
Commissioner, supra; Fowler v. Commissioner, T.C. Memo. 2004-163;
Fargo v. Commissioner, T.C. Memo. 2004-13, affd. 447 F.3d 706
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