Franklin and Janetta Hubbart - Page 15

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               Because the underlying tax liability is not at issue, our              
          review under section 6330 is for abuse of discretion.  See Sego             
          v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner,            
          114 T.C. 176, 182 (2000).  This standard does not ask us to                 
          decide whether in our own opinion petitioners’ offer-in-                    
          compromise should have been accepted, but whether respondent’s              
          rejection of the offer-in-compromise was arbitrary, capricious,             
          or without sound basis in fact or law.  Woodral v. Commissioner,            
          112 T.C. 19, 23 (1999); Keller v. Commissioner, T.C. Memo. 2006-            
          166; Fowler v. Commissioner, T.C. Memo. 2004-163.  Because the              
          same factors are taken into account in evaluating offers-in-                
          compromise based on doubt as to collectibility with special                 
          circumstances and on effective tax administration (economic                 
          hardship or considerations of public policy or equity), we                  
          consider petitioners’ separate grounds for their offer-in-                  
          compromise together.  See Murphy v. Commissioner, 125 T.C. 301,             
          309, 320 n.10 (2005), affd. 469 F.3d 27 (1st Cir. 2006); Barnes             
          v. Commissioner, T.C. Memo. 2006-150.                                       
          A.   Economic Hardship                                                      
               Petitioners assert that Ms. Cochran abused her discretion by           
          rejecting their offer-in-compromise because “There is no                    
          indication that SO Cochran gave any substantive consideration to            
          Petitioners’ demonstrated special circumstances or that they                
          would experience a hardship if required to make a full-payment.”            






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