- 28 - determination to reject petitioner’s June 28, 2005 offer-in- compromise.9 As discussed above, in that offer-in-compromise, petitioner offered $10,000 to compromise Federal tax liabilities totaling between $32,449 and $48,183.10. See supra note 7. Where, as is the case here, the validity of the underlying tax liability is not properly placed at issue, the Court will review the determination of the Commissioner of Internal Revenue for abuse of discretion. See Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000). Section 7122(a) authorizes the Secretary of the Treasury (Secretary) to compromise, inter alia, any civil case arising under the internal revenue laws. Section 7122(c) authorizes the Secretary to prescribe guidelines for the officers and the employees of the IRS to determine whether an offer-in-compromise is adequate and should be accepted to resolve a dispute. The regulations promulgated under section 7122 set forth three grounds for the compromise of a liability: (1) Doubt as to liability, (2) doubt as to collectibility, and (3) to promote effective tax administration. Sec. 301.7122-1(b), Proced. & Admin. Regs. The only ground that petitioner raised in peti- tioner’s June 28, 2005 offer-in-compromise was doubt as to collectibility. 9As discussed above, during the June 22, 2005 conference, petitioner’s authorized representative acknowledged that peti- tioner was unable to fund an installment agreement.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: November 10, 2007