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given erroneous advice and is facing additional taxes, penalties,
and additions to tax. Sec. 301.7122-1(c)(3)(iv), Proced. &
Admin. Regs. In addition to the regulations, detailed
instructions concerning offers-in-compromise are contained in the
Internal Revenue Manual. 1 Administration, Internal Revenue
Manual (CCH), pt. 5.8, at 16251.
Notwithstanding minor disputes about the computation of
collection potential by the settlement officer, petitioners have
not shown that payment of more than the amount that they offered
in settlement of their liabilities would render them unable to
meet basic living expenses. Their projections of future expenses
are speculative and unpersuasive. Petitioners’ situation is not
comparable to the examples given in the regulations. In any
event, the settlement officer thoroughly considered and addressed
their arguments.
Except for the specifics of the financial information, this
case is indistinguishable from the other cases decided by this
Court in which we held that it was not an abuse of discretion to
reject the taxpayers’ offer to compromise their outstanding
liabilities relating to the Hoyt investments at a fraction of the
total liabilities. See Smith v. Commissioner, T.C. Memo. 2007-
73; Hansen v. Commissioner, T.C. Memo. 2007-56; Catlow v.
Commissioner, T.C. Memo. 2007-47; Estate of Andrews v.
Commissioner, T.C. Memo. 2007-30; Johnson v. Commissioner, T.C.
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