- 6 - (1st Cir. 2006). The Appeals officer did not abuse his discretion by declining to delay his determinations to await the uncertain outcome of petitioner’s eleventh-hour request for audit reconsideration and the uncertain outcome of any audit reconsideration that might be granted. Petitioner contends that notwithstanding section 6330(c)(2)(B), which precluded him from challenging his underlying liability in the collection hearing, he should have been permitted to make an offer-in-compromise on the basis of doubt as to liability, pursuant to sections 6330(c)(2)(A)(iii) and 7122. The short answer is petitioner never made any offer- in-compromise. Accordingly, the Appeals officer did not abuse his discretion in failing to consider any offer-in-compromise. See Kindred v. Commissioner, 454 F.3d 688, 696 (7th Cir. 2006) (characterizing as “frivolous” an argument that the taxpayers should have been allowed to submit an offer-in-compromise in a collection hearing, where the taxpayers never actually made an offer-in-compromise); Kendricks v. Commissioner, 124 T.C. 69, 79 (2005). On the basis of our review of the record, we conclude that there is no genuine dispute as to a material fact. Petitioner has failed to make a valid challenge to the appropriateness of respondent’s intended collection action or offer alternative means of collection. In the absence of a valid issue for review,Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007