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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.
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