Christopher Cross, Inc. v. United States

BENAVIDES, Circuit Judge:

This case concerns whether an Internal Revenue Service (“IRS”) appeals officer abused her discretion in returning an offer in compromise submitted by Christopher Cross, Inc. (“Taxpayer”). Specifically, Taxpayer challenges the appeals officer’s reliance on the Internal Revenue Manual. For the reasons set forth below, we find that the appeals officer acted within her discretion in rejecting Taxpayer’s offer in compromise. Therefore, we affirm the district court’s dismissal of Taxpayer’s claims.

I. BACKGROUND

The facts are undisputed. Taxpayer admittedly owes the IRS…