Michael W. Keller et al. v. Commissioner, 2009 U.S. App. LEXIS 12043 (9th Cir., June 3, 2009)

Michael W. Keller et al. v. Commissioner, 2009 U.S. App. LEXIS 12043 (9th Cir., June 3, 2009)

Commissioner of Internal Revenue did not abuse its discretion when it rejected the taxpayers' offer of compromise because it was substantially lower than what reasonable collection potential calculation showed they could afford to pay and imposition of 26 U.S.C.S. § 6621(c) interest was proper because the transactions were overvalued or shams.
 
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