FARGO v. COMMISSIONER OF INTERNAL REVENUE
The Ninth Circuit Court of Appeals today released an opinion in FARGO v. COMMISSIONER OF INTERNAL REVENUE, No. 04-72190, a tax appeal. The panel consisted of Robert R. Beezer, Cynthia Holcomb Hall, and Kim McLane Wardlaw, Circuit Judges.
HALL, Senior Circuit Judge:
Charles and Elizabeth Fargo (Taxpayers) appeal the decision of the Tax Court holding that the Commissioner of Internal Revenue did not abuse his discretion by rejecting their offer to pay $7,500 in compromise of the approximately $104,000 interest owed on their 1983 and 1984 federal income tax liabilities. We affirm. I. Facts More than twenty years ago, Taxpayers bought interests in two partnerships: the Jackson & Associates Partnership (Jackson), and the Smith & Asher Associates Partnership (Smith & . . .