- 13 - determining the present value of the Bergevins’ future ability to pay. This was done in accordance with IRM 5.8.5.5. During the course of the negotiations through exchange of documents and meetings between petitioners’ counsel and the settlement officer, other issues were discussed. The parties disagreed as to the effect of a decision entered February 9, 2005, in an abatement action brought by petitioners in this Court. The decision provided that, with respect to the tax years 1984, 1985, and 1986, petitioners are not entitled to an abatement of interest under section 6404. In the notices of determination sent March 3, 2006, the offer-in-compromise was rejected as follows: Offers of Collection Alternatives We considered your offer of $20,652 dated September 27, 2005 and were not able to accept the offer under existing policies and procedures. * * * [Settlement Officer Dale Veer] previously provided you with the details of how this determination was made. You were given the opportunity to amend your offer to an amount not less than the current balance owed for years 1981, 1982, 1983, 1984, 1985 and 1986. You were also offered the opportunity to either pay the 1981-1986 balances in full or present an alternative proposal to the offer in compromise. You neglected all such opportunities. Discussion Petitioners invoke our jurisdiction under section 6330(d) to review the notices of determination sent to them with respect to the proposed levies on their property. Petitioners contend thatPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: March 27, 2008