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Nor have petitioners articulated with any specificity the
purported economic hardship they will suffer if they are not
allowed to compromise their liability for $35,000. While
petitioners claim generally that the sale of their residence
would create an economic hardship in that they would be unable to
afford paying either rent or a mortgage, this claim is vague,
speculative, undocumented, and unavailing.13 See Barnes v.
Commissioner, T.C. Memo. 2006-150.
We also are mindful that any decision by Cochran to accept
petitioners’ offer-in-compromise due to doubt as to
collectibility with special circumstances must be viewed against
the backdrop of section 301.7122-1(b)(3)(iii), Proced. & Admin.
Regs. That section requires that Cochran deny petitioners’ offer
if her acceptance of it would undermine voluntary compliance with
tax laws by taxpayers in general. Thus, even if we were to
assume arguendo that petitioners would suffer economic hardship,
a finding that we emphasize we decline to make, we would not find
that Cochran’s rejection of petitioners’ offer was an abuse of
discretion because we conclude below (in our discussion of
petitioners’ fifth argument) that her acceptance of that offer
13 We note that our opinion here does not necessarily mean
that respondent may in fact levy on petitioners’ residence in
payment of their tax debt. Pursuant to sec. 6334(a)(13)(B) and
(e), a taxpayer’s principal residence is exempt from levy absent
the written approval of a U.S. District Court Judge or
Magistrate. See also sec. 301.6334-1(d), Proced. & Admin. Regs.
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