Gary and Johnean Hansen - Page 17

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          considered the information actually given to her by petitioners.            
          With the exception of expenses that exceeded respondent’s                   
          guidelines and excessive claimed tax expenses, Cochran allowed              
          the full amount of petitioners’ expenses.  Moreover, Cochran                
          allowed the full $400 that petitioners claimed in medical                   
          expenses even though they provided no documentation of any such             
          expenses.  Finally, Cochran allowed petitioners more than a month           
          after their collection due process hearing to submit additional             
          documents to support their position.  We find that Cochran gave             
          thorough consideration to all of petitioners’ claims.                       
               Fourth, petitioners argue that public policy demands that              
          their offer-in-compromise be accepted because they were victims             
          of fraud.  We disagree.  While the regulations do not set forth a           
          specific standard for evaluating an offer-in-compromise based on            
          claims of public policy or equity, the regulations contain two              
          illustrative examples.  See sec. 301.7122-1(c)(3)(iv), Examples             
          (1) and (2), Proced. & Admin. Regs.  The first example describes            
          a taxpayer who is seriously ill and unable to file income tax               
          returns for several years.  The second example describes a                  
          taxpayer who received erroneous advice from the Commissioner as             
          to the tax effect of the taxpayer’s actions.  Neither example               
          bears any resemblance to this case.  See Speltz v. Commissioner,            
          454 F.3d at 786.  Unlike the exceptional circumstances                      
          exemplified in the regulations, petitioners’ situation is neither           

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