- 9 -
information as requested. Similarly, petitioner has offered no
explanation as to why his Form 433-A, submitted with his offer-
in-compromise, indicated that petitioner had the ability to pay
only $57 per month, whereas in his previously requested
installment agreement, petitioner had offered to pay $10,000 up
front and $1,000 per month thereafter.
Petitioner refers to the settlement officer’s notations on
petitioner’s Form 433-A, which petitioner interprets to mean that
the settlement officer might have been willing to consider an
offer-in-compromise of $9,558.16. Petitioner suggests that the
difference between this number and petitioner’s $7,500 offer-in-
compromise is not “meaningful” and that the settlement officer
accordingly abused his discretion in rejecting petitioner’s
$7,500 offer-in-compromise. We disagree. As the settlement
officer testified, his willingness to consider a $9,558.16 offer-
in-compromise was contingent on petitioner’s providing all the
information that had been requested. Having failed to provide
the requested information, petitioner has no cause to complain
that the settlement officer did not further explore the
possibility of an upwardly revised offer-in-compromise.
In sum, the settlement officer did not abuse his discretion
in rejecting petitioner’s offer-in-compromise. Accordingly,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011