Gary and Johnean Hansen - Page 21

                                       - 21 -                                         
          this case had she agreed to let petitioners compromise their                
          estimated $260,143 liability by paying less than the amount of              
          interest included within that liability.                                    
               We hold that Appeals did not abuse its discretion in                   
          rejecting petitioners’ $90,258 offer-in-compromise.  In so                  
          holding, we express no opinion as to the amount of any compromise           
          that petitioners could or should be required to pay, or that                
          respondent is required to accept.  The only issue before us is              
          whether Appeals abused its discretion in refusing to accept                 
          petitioners' specific offer-in-compromise in the amount of                  
          $90,258.  See Speltz v. Commissioner, 124 T.C. at 179-180.  We              
          have considered all arguments made by petitioners for a contrary            
          holding and have found those arguments not discussed herein to be           
          irrelevant and/or without merit.                                            

                                                  An appropriate order will           
                                             be issued.                               

Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  

Last modified: May 25, 2011