- 25 - reasonably expect to collect on petitioners’ liabilities. Mr. Conte concluded that respondent was likely to receive more in the distribution from the bankruptcy than from petitioners’ offer-in- compromise. Further, Mr. Conte determined that accepting petitioners’ offer would risk this expected greater distribution. We find petitioners’ offer-in-compromise was not rejected solely on the basis of the amount offered. We are not unsympathetic to petitioners’ situation as they ultimately had no control over when any distribution from the bankruptcy would be made. Since then, petitioners’ financial outlook has improved dramatically. Mr. Salazar is now employed as a manager of a restaurant and has begun receiving Social Security benefits. Mrs. Salazar completed law school and now works as an attorney. Thus, while the $9,024.25 offer-in- compromise may have been the limit of what petitioners could pay in 2004, when Mr. Salazar submitted a second offer-in-compromise during the second collection review hearing with respect to his employment tax liabilities, respondent determined that Mr. Salazar was then in a position to pay the entirety of his outstanding employment tax liabilities. Petitioners have not presented any argument or evidence to the Court to suggest that respondent’s rejection of this second offer-in-compromise was an abuse of discretion.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: March 27, 2008