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that the tax laws are being administered in a fair and equitable
manner. Respondent determined that petitioner’s reasonable
collection potential was $503,834 and that petitioner’s offer-in-
compromise did not meet the criteria for an offer-in-compromise
based on either doubt as to collectibility with special
circumstances or effective tax administration.
Insofar as the underlying tax liability is not at issue, our
review under section 6330 is for abuse of discretion.10 See Sego
v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner,
114. T.C. 176, 182 (2000). This standard does not ask us to
decide whether in our own opinion petitioner’s offer-in-
compromise should have been accepted, but whether respondent’s
rejection of the offer-in-compromise was arbitrary, capricious,
or without sound basis in fact or law. Woodral v. Commissioner,
112 T.C. 19, 23 (1999); Keller v. Commissioner, T.C. Memo. 2006-
166; Fowler v. Commissioner, T.C. Memo. 2004-163. Because the
same factors are taken into account in evaluating offers-in-
compromise based on doubt as to collectibility with special
circumstances and on effective tax administration (economic
hardship or public policy and equity), we consider petitioner’s
separate grounds for his offer-in-compromise together. See
10 With the exception of his liability for sec. 6621(c)
interest, petitioner does not argue that his underlying tax
liability is at issue. The sec. 6621(c) interest issue is
discussed infra.
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