Martin and Sharon Smith - Page 23




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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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