Gary and Johnean Hansen - Page 16

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          underlying section 7122.  Petitioners’ argument on this point is            
          essentially the same argument that was considered and rejected by           
          the Court of Appeals for the Ninth Circuit in Fargo v.                      
          Commissioner, 447 F.3d at 711-712.  We do likewise here for the             
          same reasons stated in that opinion.  We add that petitioners’              
          counsel participated in the appeal in Fargo as counsel for the              
          amici.  While petitioners in their brief suggest that the Court             
          of Appeals for the Ninth Circuit knowingly wrote its opinion in             
          Fargo in such a way as to distinguish that case from the cases of           
          counsel’s similarly situated clients (e.g., petitioners), and               
          otherwise to allow those clients to receive an abatement of their           
          liability attributable to partnerships such as those here, we do            
          not read the opinion of the Court of Appeals for the Ninth                  
          Circuit in Fargo to support that conclusion.                                
               Third, petitioners argue that Cochran inadequately                     
          considered their unique facts and circumstances.  We disagree.              
          Cochran reviewed and considered all information given to her by             
          petitioners.  On the basis of the facts and circumstances of                
          petitioners’ case as they were presented to her, Cochran                    
          determined that petitioners’ offer did not meet the applicable              
          guidelines for acceptance of an offer-in-compromise to promote              
          effective tax administration based on economic hardship or public           
          policy or equity grounds.  We find no abuse of discretion in that           
          determination.  Nor do we find that Cochran inadequately                    

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