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2007-56; Catlow v. Commissioner, T.C. Memo. 2007-47; Estate of
Andrews v. Commissioner, T.C. Memo. 2007-30; Freeman v.
Commissioner, T.C. Memo. 2007-28; Johnson v. Commissioner, T.C.
Memo. 2007-29; Abelein v. Commissioner, T.C. Memo. 2007-24;
Hubbart v. Commissioner, T.C. Memo. 2007-26; Carter v.
Commissioner, T.C. Memo. 2007-25; Ertz v. Commissioner, T.C.
Memo. 2007-15; McDonough v. Commissioner, T.C. Memo. 2006-234;
Lindley v. Commissioner, T.C. Memo. 2006-229; Blondheim v.
Commissioner, T.C. Memo. 2006-216; Clayton v. Commissioner, T.C.
Memo. 2006-188; Keller v. Commissioner, T.C. Memo. 2006-166;
Barnes v. Commissioner, T.C. Memo. 2006-150. As was equally true
as to the taxpayers in many of those prior cases, petitioners
here made a lowball offer to Appeals to compromise their tax debt
and now argue in this Court that Appeals’s rejection of their
offer was an abuse of discretion because, generally speaking,
they claim that the Appeals officer did not appreciate the
specifics of their case.
Where an underlying tax liability is not at issue in a case
invoking our jurisdiction under section 6330(d), we review a
determination of Appeals for abuse of discretion. See Sego v.
Commissioner, 114 T.C. 604, 610 (2000). We reject the
determination of Appeals only if the determination was arbitrary,
capricious, or without sound basis in fact or law. See Cox v.
Commissioner, 126 T.C. 237, 255 (2006); Murphy v. Commissioner,
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