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consider the specifics of their case.7 The Commissioner may
compromise a tax liability to promote effective tax
administration when collection of the full liability will create
economic hardship and the compromise would not undermine
compliance with the tax laws by taxpayers in general. See sec.
301.7122-1(b)(3)(i), (iii), Proced. & Admin. Regs. If a taxpayer
does not qualify for effective tax administration compromise on
grounds of economic hardship, the regulations also allow the
Commissioner to compromise a tax liability to promote effective
tax administration when the taxpayer identifies compelling
considerations of public policy or equity. See sec.
301.7122-1(b)(3)(ii), Proced. & Admin. Regs.
Driver considered all of the evidence submitted to her by
petitioners, and she applied the guidelines for evaluating an
offer-in-compromise to promote effective tax administration. She
determined that petitioners’ offer was unacceptable because,
among other reasons, they were not forthcoming in establishing
7 Petitioners’ posttrial opening brief also states as an
issue the question of whether Appeals abused its discretion by
rejecting petitioners’ request for an offer-in-compromise on the
ground of doubt as to collectibility. The brief does not,
however, advance any direct argument on this issue, stating
instead that the resolution of the issue is controlled by our
decision on petitioners’ claim of effective tax administration.
We consider petitioners to have waived any independent claim of
error related to Appeals’s rejection of their offer-in-compromise
on the ground of doubt as to collectibility and limit our
discussion to Appeals’s rejection of petitioners’ offer-in-
compromise on the ground of effective tax administration.
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