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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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