- 10 - taxpayers with the tax laws.12 Sec. 301.7122-1(b)(3), Proced. & Admin. Regs. Petitioners proposed an offer-in-compromise based on effective tax administration. Petitioners offered to pay $346,258 to compromise their outstanding tax liabilities for 1980 through 1996, which totaled $750,740 at the time of the section 6330 hearing.13 Petitioners argued that exceptional circumstances existed such that collection of the full liability would undermine public confidence that the tax laws are being administered in a fair and equitable manner. Respondent determined that petitioners’ reasonable collection potential was $1,287,552 and that their offer-in-compromise did not meet the criteria for an effective tax administration offer-in-compromise. 12 The regulations also provide that the Secretary may compromise a liability on the ground of effective tax administration when collection of the full liability will create economic hardship. See sec. 301.7122-1(b), Proced. & Admin. Regs. Respondent determined that petitioners were not entitled to an offer-in-compromise based on economic hardship. While petitioners dispute Ms. Cochran’s determination of their reasonable collection potential, they do not argue that collection of the full liability would create economic hardship. 13 The proposed collection action related to petitioners’ outstanding tax liability for 1980-85, 1989, and 1990 only. Petitioners estimated that their outstanding tax liability for those periods was $474,655. However, petitioners sought to compromise their outstanding tax liability for not only those periods, but also for 1986-88 and 1991-96. To accurately compare their offer amount to their outstanding tax liability, we must therefore consider the total assessed amount for 1980-96, and not for only 1980-85, 1989 and 1990.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011