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the backdrop of section 301.7122-1(b)(3)(iii), Proced. & Admin.
Regs.12 See Barnes v. Commissioner, T.C. Memo. 2006-150. That
section requires that Ms. Cochran deny petitioner’s offer-in-
compromise if its acceptance would undermine voluntary compliance
with tax laws by taxpayers in general. Thus, even if we were to
assume arguendo that petitioner would suffer economic hardship, a
finding that we decline to make, we would not find that Ms.
Cochran’s rejection of petitioner’s offer-in-compromise was an
abuse of discretion. As discussed below (in our discussion of
petitioner’s “equitable facts” argument), we conclude that
acceptance of petitioner’s offer-in-compromise would undermine
voluntary compliance with tax laws by taxpayers in general.
B. Public Policy and Equity Considerations
Petitioner asserts that “There are so many unique and
equitable facts in this case that this case is an exceptional
circumstance” and respondent abused his discretion by not
accepting those facts as grounds for an offer-in-compromise. In
support of his assertion, petitioner argues: (1) The
longstanding nature of this case justifies acceptance of the
offer-in-compromise; (2) respondent’s reliance on an example in
12 The prospect that acceptance of an offer-in-compromise
will undermine compliance with the tax laws militates against its
acceptance whether the offer-in-compromise is predicated on
promotion of effective tax administration or on doubt as to
collectibility with special circumstances. See Rev. Proc. 2003-
71, 2003-2 C.B. 517; IRM sec. 5.8.11.2.3; see also Barnes v.
Commissioner, T.C. Memo. 2006-150.
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