William J. and Lois J. DiCindio - Page 7




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          compromise.  The reason for the requested extension was to file             
          petitioner’s 2005 income tax return.  However, the filing of                
          petitioner’s 2005 income tax return was not a requirement of                
          respondent’s acceptance of the offer.  The OS knew that                     
          petitioner had requested an extension for filing his 2005 taxes.            
          The information that the OS needed, however, had to do with                 
          additional information to verify and confirm the data on the                
          submitted OIC.  Therefore, it was not an abuse of discretion to             
          reject petitioners’ OIC on account of their failure to submit               
          additional information before the Court ruled on petitioners’               
          pending motion for reconsideration.                                         
               We conclude that respondent may proceed with collection of             
          petitioners’ tax liabilities for 1985-89 and 1991-2001 because              
          respondent’s rejection of petitioners’ offer-in-compromise was              
          not an abuse of discretion.                                                 


                                                   Decision will be entered           
                                             for respondent.                          

















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