- 23 - 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 petitionersPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: November 10, 2007