- 26 -
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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