Gary and Johnean Hansen - Page 20

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          collection of the liabilities at issue in this case”.  While                
          petitioners assert that Cochran did not consider all of the facts           
          and circumstances of this case, “including whether the                      
          circumstances of a particular case warrant acceptance of an                 
          amount that might not otherwise be acceptable under the                     
          Secretary’s policies and procedures”, sec. 301.7122-1(c)(1),                
          Proced. & Admin. Regs., we find to the contrary.  Cochran                   
          thoroughly considered petitioners’ arguments for accepting their            
          offer-in-compromise, and she rejected the offer only after                  
          concluding that petitioners could pay much more of their tax                
          liability than the $90,258 they offered.  Cf. IRM sec.                      
 (“When hardship criteria are identified but the              
          taxpayer does not offer an acceptable amount, the offer should              
          not be recommended for acceptance”).                                        
               Sixth, petitioners argue that Cochran inappropriately failed           
          to consider whether they qualified for an abatement of interest             
          for reasons other than those described in section 6404(e).  We              
          disagree.  We note that in the notice of determination, Cochran             
          decided to stay collection of interest while petitioners’                   
          interest abatement case was pending in this Court.  Moreover, we            
          find nothing to suggest that Cochran believed that petitioners’             
          sole remedy for interest abatement in this case rested on the               
          rules of section 6404(e).  In fact, regardless of the rules of              
          section 6404(e), Cochran obviously would have abated interest in            

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