- 21 -
determined by the Calaveras County Assessor’s Office in 2002. We
find that Ms. Cochran’s use of the county assessor’s valuation
was not arbitrary or capricious.
Petitioners raise various other challenges and arguments,
including: (1) Ms. Cochran abused her discretion by taking into
consideration only future decreases in expenses and not future
increases; (2) Ms. Cochran improperly disallowed petitioners’
actual housing and utility expenses; and (3) Ms. Cochran
improperly disallowed petitioners’ actual transportation
expenses. We need not discuss in detail these and other minor
disputes raised by petitioners. Even assuming arguendo that
petitioners’ income, expenses, and value of assets should have
been accepted as reported, we would not find that Ms. Cochran
abused her discretion in rejecting petitioners’ offer-in-
compromise. Ms. Cochran testified that, had she accepted the
income, expenses, and value of assets as reported, petitioners’
reasonable collection potential would have been $178,656.
Petitioners offered to pay only $60,400 to compromise their
outstanding tax liability. In some situations, respondent may
accept an offer amount of less than petitioners’ reasonable
collection potential. However, given all other considerations
discussed herein, we do not believe that Ms. Cochran abused her
discretion by rejecting an offer-in-compromise that bore no
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011