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petitioner’s response to the settlement officer’s request for
additional information was inadequate to permit the settlement
officer to make a reasonable analysis of petitioner’s offer-in-
compromise.4
OPINION
Petitioner does not dispute his underlying tax liability.
We review the settlement officer’s rejection of petitioner’s
offer-in-compromise for abuse of discretion. Goza v.
Commissioner, 114 T.C. 176, 182 (2000).
Petitioner contends that the settlement officer abused his
discretion in rejecting petitioner’s offer-in-compromise.
Petitioner does not dispute that the settlement officer requested
additional information that petitioner never provided.
Petitioner contends, however, that he provided all the
information that he had available, which he says was “complete
and current from his point of view”. Petitioner suggests that
the burden was on the settlement officer to develop any
additional information which the settlement officer might wish to
4 In the notice of determination, the settlement officer
also considered petitioner’s previous request for an installment
agreement, even though petitioner had not raised this issue at
the collection hearing. The settlement officer rejected the
requested installment agreement on the ground that the proposed
payments would not fully pay petitioner’s tax liabilities within
the expiration date for collection. Petitioner has not
challenged this determination in this proceeding.
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Last modified: May 25, 2011