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liability to promote effective tax administration. Petitioners
contended that Appeals should accept their offer as a matter of
equity and public policy. Petitioners stated that it took a long
time to resolve the Hoyt partnership cases and noted that Hoyt
had been convicted on the criminal charges. The second issue
concerned an interest abatement case under section 6404(e) that
petitioners then had pending in this Court at docket No.
18896-03. That case related to 1989, the year at issue here, and
petitioners claimed that the proposed levy should be rejected
because the case was pending. On April 28, 2005, the Court
entered a decision in that case stating that the parties agreed
that petitioners were not entitled for 1989 to an abatement of
interest under section 6404. That decision is now final.
On February 15, 2005, petitioners tendered to Cochran on
Form 656, Offer in Compromise, a written offer to pay $90,258 to
compromise their estimated $260,143 liability. The offer was
limited to a claim of effective tax administration because
petitioners had sufficient assets to pay their tax liability in
full. Petitioners supplemented their offer with a completed Form
433-A, Collection Information Statement for Wage Earners and
Self-Employed Individuals, four letters totaling approximately 65
pages, and volumes of documents. The Form 433-A reported that
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Last modified: May 25, 2011