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rely upon to reject petitioner’s offer-in-compromise.
Petitioner’s contentions are unpersuasive.
When requesting an offer-in-compromise, the taxpayer must
provide complete and current financial information sufficient to
enable the Appeals officer to adequately evaluate the offer.
Sec. 301.7122-1(d)(2), Proced. & Admin. Regs. If the taxpayer
fails to do so, the offer-in-compromise may be rejected. See,
e.g., Shrier v. Commissioner, T.C. Memo. 2006-181; Picchiottino
v. Commissioner, T.C. Memo. 2004-231; Willis v. Commissioner,
T.C. Memo. 2003-302.
The settlement officer did not abuse his discretion in
finding that petitioner’s responses to requests for additional
information were insufficient to permit a reasonable analysis of
petitioner’s offer-in-compromise. The answers that petitioner
provided to the settlement officer’s September 7, 2004, request
for additional information were incomplete and insufficient to
resolve legitimate questions raised by the settlement officer as
to apparent discrepancies between petitioner’s reported financial
information and the provisions of the marital settlement. For
example, although the marital settlement indicated that Ms. Kerr
had relinquished any interest in RMC, petitioner represented to
the settlement officer, without supporting documentation, that
RMC was wholly owned by Ms. Kerr. Petitioner has not credibly
explained these inconsistencies or his failure to submit complete
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