Roger D. and Mary M. Catlow - Page 14

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          Regs.  If a taxpayer does not qualify for the just stated                   
          effective tax administration compromise on grounds of economic              
          hardship, and does not qualify for an offer-in-compromise due to            
          doubt as to either liability or collectibility, the regulations             
          also allow the Commissioner to compromise a tax liability to                
          promote effective tax administration when the taxpayer identifies           
          compelling considerations of public policy or equity.  See sec.             
          301.7122-1(b)(3)(ii), Proced. & Admin. Regs.                                
               Petitioners made their offer-in-compromise due to doubt as             
          to collectibility with special circumstances and to promote                 
          effective tax administration.  Petitioners reported on their Form           
          433-A that they had assets worth $169,650 (i.e., their assets’              
          total reported current value of $177,598 minus a $7,948                     
          encumbrance on their VW Passat).  Cochran determined petitioners’           
          reasonable collection potential to be $193,438.  Therefore,                 
          petitioners cannot fully pay their estimated $575,000 tax                   
          liability and thus do not qualify for an offer-in-compromise to             
          promote effective tax administration.  See sec. 301.7122-1(b)(3),           
          Proced. & Admin. Regs.; cf. Fargo v. Commissioner, 447 F.3d 706             
          (9th Cir. 2006) (taxpayers made an offer-in-compromise to promote           
          effective tax administration where they had sufficient assets to            
          pay their tax liability in full).  As to petitioners’ offer-in-             
          compromise due to doubt as to collectibility with special                   
          circumstances, the Commissioner evaluates such an offer by                  






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