Roger D. and Mary M. Catlow - Page 25

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          Secretary’s policies and procedures”, sec. 301.7122-1(c)(1),                
          Proced. & Admin. Regs., we find to the contrary.  Cochran                   
          thoroughly considered petitioners’ arguments for accepting their            
          offer-in-compromise, and she rejected the offer only after                  
          concluding that petitioners could pay much more of their tax                
          liability than the $35,000 they offered.  Cf. IRM sec.                      
          5.8.11.2.1(11) (“When hardship criteria are identified but the              
          taxpayer does not offer an acceptable amount, the offer should              
          not be recommended for acceptance”).                                        
               Seventh, petitioners argue that Cochran inappropriately                
          failed to consider whether they qualified for an abatement of               
          interest for reasons other than those described in section                  
          6404(e).  We disagree.  While Cochran declined to accept                    
          petitioners’ request to reject the proposed levy because she had            
          considered their request for interest abatement and found that              
          they were not entitled to such relief, we find nothing to suggest           
          that Cochran believed that petitioners’ sole remedy for interest            
          abatement in this case rested on the rules of section 6404(e).              
          In fact, regardless of the rules of section 6404(e), Cochran                
          obviously would have abated interest in this case had she agreed            
          to let petitioners compromise their estimated approximately                 
          $575,000 liability by paying less than the amount of interest               
          included within that liability.                                             
               Eighth, petitioners argue that Cochran erred by not                    
          informing petitioners of the contents of the notice of                      




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