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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.
5.8.11.2.1(11) (“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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