- 25 - 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 ofPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011