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liability for the amount has been fully satisfied. Thus
respondent argues, if respondent were to accept an offer-in-
compromise and the liabilities were thereby fully satisfied, he
would jeopardize any secured claim to the bankruptcy
distribution. Accordingly, as respondent’s counsel argues, an
offer-in-compromise will not be accepted while a bankruptcy is
pending if the offer is less than the amount he reasonably stands
to receive when the bankruptcy distribution occurs.
We believe, however, that respondent’s risk, or at least his
perceived risk, goes beyond simply the release of any secured
claim he has to the bankruptcy distribution. If an offer-in-
compromise must include all of the outstanding liabilities of the
taxpayer, then acceptance and satisfaction of the offer would
risk, if not extinguish, all claims the Commissioner had to the
bankruptcy assets. The administrative record suggests it was
this more generalized risk, to all of respondent’s claims, that
concerned Mr. Conte in evaluating petitioners’ offer-in-
compromise. Nonetheless, petitioners fail to point to any
authority to suggest that respondent’s position that accepting an
offer-in-compromise jeopardized the bankruptcy distribution was
without legal basis, and the Court knows of none.
In furtherance of their argument that the bankruptcy
distribution was not at risk, petitioners highlight their offer
to relinquish any claim to the bankruptcy distribution for the
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