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to request more information or to view the house in person. The
burden was on petitioner to establish that he was entitled to an
offer-in-compromise. Petitioner cannot shift this burden by
simply inviting Ms. Cochran to request more information or to
view the house in person.
Additionally, even assuming arguendo that petitioner’s house
valuation should have been accepted, we would not find that Ms.
Cochran abused her discretion in rejecting petitioner’s offer-in-
compromise based on economic hardship. On his Form 433-A,
petitioner reported assets with a total value of $297,742.
However, petitioner offered to pay only $157,824 to compromise
his outstanding tax liabilities. Respondent may accept an offer-
in-compromise based on doubt as to collectibility with special
circumstances or on effective tax administration even if the
offer is less than petitioner’s reasonable collection potential.
However, given all other considerations discussed herein, we do
not believe that Ms. Cochran abused her discretion by rejecting
an offer-in-compromise that bore no relationship to petitioner’s
ability to pay.
4. Encouraging Voluntary Compliance With the Tax Laws
We are also mindful that any decision by Ms. Cochran to
accept petitioner’s offer-in-compromise based on doubt as to
collectibility with special circumstances or effective tax
administration based on economic hardship must be viewed against
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