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Fourth, petitioners argue that Driver inappropriately failed
to consider whether they qualified for an abatement of interest
for reasons other than those described in section 6404(e). We
disagree. We find nothing to suggest that Driver believed that
petitioners’ sole remedy for interest abatement in this case
rested on the rules of section 6404(e). In fact, regardless of
the rules of section 6404(e), Driver obviously would have abated
interest in this case had she agreed to let petitioners
compromise their liability by paying less than the amount of
interest included within that liability. All the same, we find
no basis in the evidence for an abatement of interest, nor any
abuse of discretion by Driver in denying their request for
abatement. Cf. Mekulsia v. Commissioner, 389 F.3d 601 (6th Cir.
2004).
We hold that Appeals (acting through Driver) did not abuse
its discretion in rejecting petitioners’ $11,552 offer-in-
compromise. In so holding, we express no opinion as to the
amount of any compromise that petitioners could or should be
required to pay, or that respondent is required to accept. The
only issue before us is whether Appeals abused its discretion in
refusing to accept petitioners' specific offer-in-compromise in
the amount of $11,552. See Speltz v. Commissioner, 124 T.C. at
179-180. We have considered all arguments made by petitioners
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