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liability would undermine public confidence that the tax laws are
being administered in a fair and equitable manner; and (3)
compromise of the liability would not undermine compliance by
taxpayers with the tax laws. Sec. 301.7122-1(b)(3), Proced. &
Admin. Regs.
Ms. Cochran determined that petitioner could not afford to
pay his outstanding tax liability in full and therefore did not
qualify for an effective tax administration offer-in-compromise.
Petitioner does not argue that he has the ability to pay his tax
liability in full. Because he did not have the ability to pay
his outstanding tax liability in full, petitioner does not
qualify for an effective tax administration offer-in-compromise.
See Barnes v. Commissioner, T.C. Memo. 2006-150; sec. 301.7122-
1(b)(3), Proced. & Admin. Regs. Ms. Cochran’s determination that
petitioner did not qualify for an effective tax administration
offer-in-compromise was not arbitrary or capricious and was not
an abuse of discretion.
B. Doubt as to Collectibility With Special Circumstances
The Secretary may compromise a tax liability based on doubt
as to collectibility where the taxpayer’s assets and income are
less than the full amount of the assessed liability. Sec.
301.7122-1(b)(2), Proced. & Admin. Regs. Generally, under the
Commissioner’s administrative pronouncements, an offer-in-
compromise based on doubt as to collectibility will be acceptable
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