Roger D. and Mary M. Catlow - Page 26

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          determination before it was issued.  We disagree.  We do not                
          believe that Cochran abused her discretion by rejecting                     
          petitioners’ offer-in-compromise simply because she may not have            
          discussed with petitioners the contents of the notice of                    
          determination (and given them a chance to dispute it) before                
          issuing the notice of determination to them.  Cf. Fargo v.                  
          Commissioner, 447 F.3d at 712-713 (holding that Appeals has no              
          duty to negotiate with a taxpayer before rejecting the taxpayer’s           
          offer-in-compromise).                                                       
               We hold that Appeals did not abuse its discretion in                   
          rejecting petitioners’ $35,000 offer-in-compromise.  In so                  
          holding, we express no opinion as to the amount of any compromise           
          that petitioners could or should be required to pay, or that                
          respondent is required to accept.  The only issue before us is              
          whether Appeals abused its discretion in refusing to accept                 
          petitioners’ specific offer-in-compromise in the amount of                  
          $35,000.  See Speltz v. Commissioner, 124 T.C. at 179-180.  We              
          have considered all arguments made by petitioners for a contrary            
          holding and have found those arguments not discussed herein to be           
          without merit.                                                              

                                                       An appropriate order           
                                                  will be issued.                     








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