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effective tax administration offer-in-compromise based on
economic hardship because he had the ability to pay his tax
liability in full. Finally, respondent rejected petitioner’s
effective tax administration offer-in-compromise based on public
policy or equity grounds because the case “fails to meet the
criteria for such consideration”.
Regarding section 6621(c) interest, respondent determined
that petitioner “has not established why [tax-motivated interest]
was improperly assessed”.
Respondent concluded that petitioner did not offer an
acceptable collection alternative, that all requirements of law
and administrative procedure had been met, and that respondent
could proceed with the proposed collection action.
In response to the notice of determination, petitioner filed
his petition with this Court on October 25, 2004.
OPINION
I. Petitioner’s Offer-in-Compromise
Section 7122(a) provides that “The Secretary may compromise
any civil * * * case arising under the internal revenue laws”.
Whether to accept an offer-in-compromise is left to the
Secretary’s discretion. Fargo v. Commissioner, 447 F.3d 706, 712
(9th Cir. 2006), affg. T.C. Memo. 2004-13; sec. 301.7122-1(c)(1),
Proced. & Admin. Regs.
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