Certified Specialist In Taxation Law
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Certified Specialist In Taxation Law |
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OFFER IN COMPROMISE IRS ANNOUNCES EXPANSION OF OFFERS IN COMPROMISE PROGRAM The IRS has announced changes to its Offers in Compromise program that it says will make it easier for taxpayers to apply for and obtain help in paying their taxes. News Release IR-1999-30. The IRS announced what it calls fundamental changes in its Offers in Compromise program, which are intended to make it easier for taxpayers to apply for help and allow the IRS to be more flexible when considering taxpayer offers to settle tax bills. According to the IRS, the new program will feature additional flexibility in evaluating taxpayer expenses, more flexible rules for processing taxpayer offers, less documentation for smaller compromise offers, new deferred payment procedures, and new independent reviews for each rejected compromise offer. In addition, specially trained IRS experts will be devoted to handling compromise offers, to bring more consistency to the program. The new procedures will be included in an updated version of the Internal Revenue Manual, expected in April. The IRS made these changes in response to a provision in the IRS Reform and Restructuring Act that called for an expansion of the program. It intends to make further changes in the future to reflect other changes made by the Act. Specifically, it intends to publish regulations later this year that will create a new category of compromise offers, focusing on equity and hardship factors affecting taxpayers seeking compromise offers. Taxpayers use Form 656, Offer in Compromise, to apply for an offer in compromise. The IRS has revised the form to reflect the new procedures. Changes include the requirement of only 48 months of future income for payments made within 90 days; clearer rules for evaluating assets, along with an upfront reduction of 20 percent in the fair market value of assets, and innocent spouse protection for joint compromise agreements. General Analysis As a policy matter, the IRS is favorably inclined to settle a delinquent account when it is not collectible in full and criminal proceedings are not pending or contemplated. Translating this policy to practice is not always easy. Frivolous offers or offers submitted for the purpose of delaying the collection of tax liabilities will be immediately rejected. In 1998, Congress sought to expand the availability of compromise agreements based on a belief that the ability to compromise tax liability enhances taxpayer compliance. Congress took the position that the IRS should be more flexible in finding ways to work with taxpayers who are sincerely trying to meet their obligations and remain in the tax system. Accordingly, the IRS should make it easier for taxpayers to enter into offer-in-compromise agreements and should do more to educate the taxpaying public about the availability of such agreements. H.Rep.105-599, 105th Cong., 2d Sess., IRS Restructuring and Reform Act, Pub. L. 105-206 (July 22, 1998). As a result of these directions, the IRS instituted a more liberal acceptance policy for offers in compromise. In News Release IR-1999-30 (March 29, 1999), the IRS announced what it calls fundamental changes in its offers-in-compromise program. The changes are intended to make it easier for taxpayers to apply for help and allow the IRS to be more flexible when considering offers to settle tax bills. The new program features additional flexibility in evaluating taxpayer expenses, more flexible rules for processing offers, less documentation for smaller offers, new deferred payment procedures, and new independent reviews for rejected offers. In addition, specially trained IRS agents will be devoted to handling compromise offers to bring more consistency to the program. The News Release states that new regulations and changes to the Internal Revenue Manual are forthcoming. (a) GROUNDS FOR COMPROMISE After the IRS has assessed tax liability, the amount may be compromised only on one or both of two grounds: (1) doubt as to liability, or (2) doubt as to collectibility of the amount assessed 301.7122-1(a). No liability may be compromised if the liability has been established by a judgment or is certain and there is no doubt as to the ability of the IRS to collect the amounts owing. Reg. Section 301.7122-1(a) flush language. Criminal tax liability may be compromised only in limited circumstances. Criminal liability will not be compromised unless it involves only regulatory provisions of the Code and related statutes. If the violations of those regulatory provisions are deliberate and with the intent to defraud, the liability will not be compromised 601.203(a)( Code Section 7122 establishes the IRS's authority to compromise a tax, but the process by which the government and a taxpayer enter a binding compromise agreement is governed by contract law. The requirements of doubt as to liability or doubt as to collectibility are not mere directions. They are jurisdictional prerequisites to a valid compromise. The IRS's authority to enter into a valid compromise agreement only exists when the terms of the statute have been strictly complied with. If the IRS fails to comply with the statute, the agreement binds neither the taxpayer nor the government. Botany Worsted Mills v. United States, 278 U.S. 282 (1929). Policy changes adopted during 1998 have made it easier for a taxpayer to reach a compromise with the IRS by instituting a "liberal acceptance policy." Effective with respect to proposed offers of compromise submitted after July 22, 1998, the Secretary is directed by Code Section 7122(c) to provide guidelines to determine whether a proposed offer is adequate and should be accepted. Code Section 7122(c)(1). The guidelines are to include schedules of national and local allowances designed to ensure that taxpayers entering into a compromise have an adequate means to provide for basic living expenses. Code Section 7122(c)(2)(A). The IRS must determine, on the basis of the facts and circumstances of each taxpayer whether the use of the schedules is appropriate. The IRS cannot use the schedules if using them would result in the taxpayer not having adequate means to provide for basic living expenses 7122(c)(2)( In enacting this provision, Congress anticipated that the IRS would take into account factors such as equity, hardship, and public policy where a compromise of an individual taxpayer's income tax liability would promote effective tax administration. Congress anticipated that, among other situations, the IRS may utilize this new authority to resolve longstanding cases by forgoing penalties and interest which have accumulated as a result of delay in determining the taxpayer's liability. H. Rep. 105-599, 105th Cong., 2d Sess., Internal Revenue Service Restructuring and Reform Act (1998). In addition to the anticipated guidelines, the IRS is subject to a few specific rules in evaluating offers in compromise. The IRS cannot reject an offer in compromise from a low-income taxpayer solely on the basis of the amount of the offer. Code Section 7122(c)(3)(A). In addition, in the case of an offer in compromise based on doubts as to liability, the offer may not be rejected solely because the IRS is unable to locate the taxpayer's return or return information to verify the amount of the liability, and the taxpayer may not be required to provide a financial statement. Code Section 7122(c)(3)(B). An offer based on doubt as to liability must have room for mutual concessions on the issues before the IRS will consider a compromise. No adjustment can be made on the basis of doubt as to liability if the tax liability has been conclusively determined by a closing agreement, a final Tax Court decision, or other judicial determination. Doubt as to liability means more than a mere suspicion of doubt or a mere possibility of a different result; the taxpayer's contentions should be supported by "tangible" evidence and provide a thorough explanation of the basis for asserting that liability is doubtful. If the IRS accepts the offer, the IRS will recompute the liability under consideration using the facts, the taxpayer's contentions, and the Collections employee's conclusions as to the correctness of the liability. The agent has to consider the collection potential of the offer in compromise. As a general rule, an agent cannot consider an offer based on doubt as to collectibility if the ability of the government to collect the liability is not in doubt. Reg. Section 301.7122-1(a). An offer is appropriate when: liquidation of assets or maximum levy of income is insufficient to pay the tax; a non-liable spouse, friend, or relative may help if a compromise is made available; or additional assets are available for consideration that are exempt from levy or unreachable by other collection procedures. PRACTICE TIP: If the taxpayer has a spouse, parent, friend, or relative who is willing to help with payment of the tax liability, the taxpayer may be able to succeed with an offer in compromise by obtaining a statement that the assistance will be available if the compromise is accepted. An offer based on doubt as to collectibility must reflect the taxpayer's maximum capacity to pay. An offer that is small in relation to the tax obligation may be justified if: (1) the taxpayer is unable to generate more income; (2) the taxpayer is a defunct entity with little chance of obtaining new assets; or (3) a collateral agreement covering future income will generate a significant amount. The IRS usually will defer collection while an offer in compromise is under consideration, provided the government's interests are not jeopardized by the delay. Reg. Section 301.7122-1(d)(2). For offers in compromise pending on or made after December 31, 1999, the IRS may not collect a tax liability by levy during the period that an offer in compromise for the liability is pending, during the 30 days following rejection of an offer, and during any period in which an appeal of the rejection of an offer is being considered. Code Section 6331(k)(1). Taxpayers whose offers are rejected and who made good This prohibition on collection by levy will not apply if the IRS determines that collection is in jeopardy or that the offer was submitted solely to delay collection. H. Rep. 105-599, 105th Cong., 2d Sess., Internal Revenue Service Restructuring and Reform Act (1998). (b) COMPROMISE AGREEMENTS Written closing agreements under Code Section 7121 and written compromise agreements under Code Section 7122 are the exclusive means for the IRS to make a formal, binding settlement of civil tax liabilities. Driskill v. Commissioner, T.C. Memo. 1994-620. An offer in compromise is considered accepted only when the taxpayer is so notified in writing. A compromise agreement encompasses the entire tax Reg. Section 301.7122-1(c). The agreement may relate to civil as well as criminal liability. Reg. Section 301.7122-1(b). An offer in compromise will not be accepted unless the taxpayer waives the running of the statutory period of limitations on both or either assessment or collection of the tax liability involved for the period during which the offer is pending, or the period during which any installment remains unpaid, and for one year thereafter. Reg. Section 301.7122-1(f). IRS Form 656 provides that the taxpayer agrees to this suspension of the limitations periods on assessment and collection. taxpayer who is near the end of the ten-year collections period may be best advised not to submit an offer in compromise, because filing of the offer adds a year to the collections period. Form 656 contains a signature line for an IRS official to acknowledge the taxpayer's waiver of the statute of limitations. The IRS official's signature on this line does not constitute an acceptance of the offer in compromise. Streck v. Commissioner, T.C. Memo. 1997-407; aff'd, No. 98-1064 (6th Cir. June 16, 1999). If an offer involving more than $50,000 is accepted, a written opinion from the Chief Counsel of the IRS is required. The opinion must include the reasons for the acceptance, a statement of the amount of tax assessed, the amount of interest, additions to tax, or penalty on that tax, and the amount paid in accordance with the terms of the compromise. Neither the taxpayer nor the IRS can reopen a case after accepting a compromise agreement unless (1) the taxpayer falsified or concealed assets, or (2) the taxpayer and the IRS were mutually mistaken as to material facts. Reg. Section 301.7122-1(c). Rescission due to fraud or mutual mistake is a principle of contract law. In Timms v. United States, 678 F.2d 831 (9th Cir. 1982), cert. denied, 459 U.S. 1086 (1982), the court applied contract principles to offers in compromise, stating that the 'rule of law' normally applicable to a Code Section 7122 compromise agreement is that such compromises are final and may not be reopened in the absence of fraud or mutual mistake. In order for the IRS to reopen a case based on the taxpayer's concealment of his ability to pay, the Ninth Circuit requires that the IRS actually relied on the taxpayer's false statements in entering the compromise agreement. In re Jones, 79 AFTR2d 87-2569 (BAP 9th Cir. 1997) If reliance were not required, the IRS could simply accept an offer in compromise it knows to contain false statements and at some future point, if the taxpayer's assets were to increase in value, rescind the offer and collect again. As a condition to accepting an offer in compromise, the IRS may require the taxpayer to enter a collateral agreement or post any security deemed necessary to protect the interests of the United States. A collateral agreement enables the IRS to collect funds in addition to the amount actually secured via the offer in compromise. Collateral agreements are not routinely secured but secured only when a significant recovery can reasonably be expected. For example, an agreement would be appropriate when it is reasonably expected that the taxpayer will be receiving a substantial increase in real income, whereas, an agreement would not be entered merely on unfounded speculation about a real increase in income. Collateral agreements are filed on Form 2261, Future Income-Individual; Form 2261-A, Future Income-Corporation; Form 2261-B, Adjusted Basis of Specific Assets; Form 2261-C, Waiver of Net Operating Losses, Capital Losses, and Unused Investment Credits. The purpose of the collateral agreement requirement is to recoup funds representing the amount the government has "lost" in the compromise. Recoupment is limited to the liability "lost." Collateral agreements are not a substitute for an offer in compromise and may not reduce the amount of tax based on inability to pay. Collateral agreements are accepted with the offer in compromise and their acceptance is conditioned on the taxpayer's waiver of the collection period. (c) COMPROMISE PROCEDURES A taxpayer submits an offer in compromise on IRS Form 656. If the basis of the offer is doubt as to liability, the taxpayer must submit a written statement describing in detail why he does not believe he owes the liability. If collectibility is an issue, the taxpayer must submit IRS Form 433, Collection Information Statement. COMPLIANCE TIP: File the offer in compromise with the district director or service center director. Reg. Section 601.203(b). The IRS's position is to be carefully neutral when discussing an offer in compromise. Employees are cautioned against suggesting terms, suggesting a taxpayer submit an offer, or suggesting that discussion of an offer constitutes acceptance by the IRS. But if the collection officer concludes that a compromise would be in the government's interest, the officer is expected to explain compromise procedures and inform the taxpayer of the taxpayer's right to make an offer. Offers in compromise should generally be accompanied by a remittance representing the amount of the compromise offer or a deposit if the offer provides for future installment payments. However, a deposit is not required. Reg. Section 301.7122-1(d)(1). If the final payment on an accepted offer is contingent upon the immediate or simultaneous release of a tax lien in whole or in part, payment must be by cash, certified check, or money order. Reg. Section 301.7122-1(d)(1). If an offer of compromise is withdrawn or rejected, the amount tendered with the offer, including all installments paid, must be refunded without interest to the taxpayer, unless the taxpayer has agreed to have that amount applied to the tax liability. The IRS prefers that an offer based on collectibility be accompanied by a waiver of refund of the deposit if the offer is not accepted. When the deposit on the offer is retained, a closing letter is sent stating the retention of the deposit and how it is applied to the tax liability. A conference can be scheduled with the examiner or the official considering the offer prior to its formal submission. submit a written protest to Appeals. Reg. Section 601.203(d). Otherwise, the request may be in writing or oral. The taxpayer may withdraw an offer in compromise at any time prior to its acceptance. Reg. Section 301.7122-1(d)(4). The IRS will prepare a memorandum confirming the withdrawal on IRS Form 1271 and may reactivate collection status. Effective with respect to proposed offers of compromise submitted after July 22, 1998, Code Section 7122(d) directs the Secretary to establish procedures for an independent administrative review of any proposed rejection of an offer in compromise before the rejection is communicated to the taxpayer. The procedures must also allow the taxpayer to appeal any rejection to the IRS Office of Appeals. Code Section 7122(d). Effective July 22, 1998, the Secretary is directed to establish procedures for dispute resolution. Code Section 7123(a). Either the taxpayer or the IRS Office of Appeals may request non-binding mediation on any unresolved issue after either the appeals procedure or an unsuccessful attempt to reach a closing agreement or a compromise. Code Section 7123(b)(1). Similarly, the taxpayer and the IRS Office of Appeals jointly may request binding arbitration on any unresolved issue after either the appeals procedure or an unsuccessful attempt to reach a closing agreement or a compromise. Code Section 7123(b)(2). If the IRS rejects an offer, the taxpayer must be given prompt written notice of the rejection. Reg. Section 301.7122-1(d)(4). The taxpayer can then request a meeting with the office having jurisdiction to discuss an acceptable compromise. If agreement is not reached during this meeting, the taxpayer can protest to Appeals. The protest must be in writing if the tax exceeds $2,500 for any return or taxable year. Code Section 7122 gives the Secretary or his delegate the authority to enter into compromise agreements. The issue may arise as to who can accept an offer on behalf of the IRS. Compromise authority has been delegated to various officers in the IRS, including the district director, but not to revenue officers. Thus, a revenue officer can negotiate a compromise, but has no authority to bind the IRS. An offer in compromise is first considered by the district director having jurisdiction. The examining officer makes a written recommendation for acceptance or rejection of the offer. If the director has jurisdiction over the processing of the offer, he may reject it; accept it if it involves civil liability under $500; accept it if it involves civil liability of more than $500 but less than $100,000 and the District Counsel concurs in the acceptance; or recommend to the Regional Commissioner the acceptance of the offer if it involves a civil liability of $100,000 or over. Reg. Section 601.203(c)(1). The district director can reject any offer, but the taxpayer can appeal the rejection either to the official having acceptance authority or to Appeals. The authority to accept offers in compromise in civil cases involving liability of $100,000 or more, based solely on doubt as to liability, has been delegated to regional commissioners and, for cases arising in the District Office, Foreign Operations District to the Assistant Commissioner (Compliance). Reg. Section 601.203(a)(1). The authority concerning liability of $100,000 or more based on doubt as to collectibility or doubt as to both collectibility and liability has been delegated to the Director, Collection Division, and regional commissioners. Reg. Section 601.203(a)(1). The authority with respect to compromise of civil cases involving liability under $100,000, and of certain specific penalties, has been delegated to district directors, assistant district directors, regional directors of Appeals, and chiefs and associate chiefs, Appeals offices. Reg. Section 601.203(a)(1). The authority concerning offers in compromise of penalties based solely on doubt as to liability, if the liability is less than $100,000, has also been delegated to service center directors and assistant service center directors. Reg. Section 601.203(a)(1). In civil cases involving liability of $500 or more and in criminal cases, the functions of the General Counsel are performed by the Chief Counsel for the IRS; these functions are performed in the District Counsel, Regional Counsel, or National Office as appropriate. authority to accept a compromise (Code Section 7122) authority to act has been delegated by Del. Order No. 11 (Rev. 24), 1994-2 C.B. 550. An offer based on inability to pay (doubt as to collectibility) results in the case being transferred from Appeals to Collection. If Collection rejects the offer, the taxpayer can protest the rejection back to Appeals. The IRS has the authority to reject an offer if it could cause negative perceptions among the public. The IRS tries to limit perceptions of unfair advantage or tax evasion. Authority to reject offers in compromise for public policy reasons is restricted and may not be redelegated below service center directors. Accepted offers in compromise are public information. They are available for inspection in the office of the General Counsel for the Treasury Department. Effective for offers of compromise accepted on or after July 30, 1996, however, an opinion of the General Counsel of the Treasury or Chief Counsel of the IRS explaining the details of the compromise need not be placed on file for any civil case in which the amount of tax assessed (including any interest, additional amount, addition to the tax, or assessable penalty) is less than $50,000. The ultimate goal of an offer-in-compromise is a settlement that is in both the Government's and the taxpayer's best interest. The IRS will accept an offer-in-compromise to settle unpaid accounts for less than the amount owed when doubt exists as to whether you owe the liability, or when there is doubt that the liability can be collected in full and the amount you offer reasonably reflects collection potential. This may be an alternative for resolving your tax delinquency.If the basis of the offer is doubt that you owe the liability, for example, a disputed assessment, you must provide a written statement of supporting evidence. The Service cannot accept a compromise where the liability has already been decided by a court. Forms to File and Requirements To submit an offer-in-compromise you must complete Form 656; complete instructions are provided on the form. Also, you must submit Form 433-A, Collection Information Statement for Individuals, or Form 433-B, Collection Information Statement for Businesses, if the basis of the offer is doubt that the liability can be collected in full. These forms provide a statement of your income, expenses, assets, and liabilities. The amount of the offer should at least equal or exceed your equity in all assets. When reviewing an offer, the IRS considers four factors:
It is your responsibility to show how acceptance of the offer would be in the best interest of the Government. Generally, the IRS will not accept an offer unless it is clear that you have complied with all current filing and paying requirements. The acceptance of an offer creates a "fresh start"; therefore, the terms of the offer require future compliance with all tax filing and paying requirements for a period of 5 years. If you do not abide by all the terms of the offer, including the compliance requirement, the IRS may reinstate the entire tax liability Excerpts From the IRS Manual, Regulation, Conference Report and law The tax policy for Offers in Compromise is stated in 57(10)1 of the IRS Manual: It states that the compromise process is available "to provide delinquent taxpayers with a fresh start toward future compliance with the tax laws."Section 57(10)1 IR Manual states: Policy Statement P-5-100 sets forth the Service’s position on using compromises. The Service will accept an Offer in Compromise when it is unlikely that the tax liability can be collected in full and the amount offered reasonably reflects collection potential. An offer in compromise is a legitimate alternative to declaring a case as currently not collectible or to a protracted installment agreement. The goal is to achieve collection of what is potentially collectible at the earliest possible time and at the least cost to the government. The success of the compromise program will be assured only if taxpayers make adequate compromise proposals consistent with their ability to pay and the Service makes prompt and reasonable decisions. Taxpayers are expected to provide reasonable documentation to verify their ability to pay. The ultimate goal is a compromise which is in the best interest of both the taxpayer and the Service. Acceptance of an adequate offer will also result in creating, for the taxpayer, an expectation of and a fresh start toward compliance with all future filing and payment requirements. Section 57(1)1.2 of IR manual deals with the IRS Compromise Objectives: (1) To resolve accounts receivable which cannot be collected in full or on which there is a legitimate dispute as to what is owed. (2) To effect collection of what could reasonably be collected at the earliest time possible at the least cost to the government. (3) To give taxpayers a fresh start to enable them to voluntarily comply with the tax law (4) To collect funds which may not be collectible through any other means. An offer in compromise relates to the entire tax liability of the taxpayer
and all question of that liability will be conclusively settled in that
agreement. (1) IN GENERAL — The Secretary shall prescribe guidelines for officers
and employees of the Internal Revenue Service to determine whether an
offer-in-compromise is adequate and should be accepted to resolve a dispute.
(3) SPECIAL RULES RELATING TO TREATMENT OF OFFERS.—
The Code permits the IRS to compromise a taxpayer’s tax liability. An offer-in-compromise is an offer by the taxpayer to settle unpaid tax accounts for less than the full amount of the assessed balance due. An offer-in-compromise may be submitted for all types of taxes, as well as interest and penalties, arising under the Internal Revenue Code. There are two bases on which an offer can be made: doubt as to liability for the amount owed and doubts as to the ability to pay the amount owed. A compromise agreement based on doubt as to ability to pay requires the taxpayer to file returns and pay taxes for five years from the date the IRS accepts the offer. Failure to do so permits the IRS to begin immediate collection actions for the original amount of the liability. The Internal Revenue Manual provides guidelines for revenue officers to determine whether an offer-in-compromise is adequate. An offer is adequate if it reasonably reflects collection potential. Although the revenue office is instructed to consider the taxpayer'’ assets and future and present income, the IRS advises that rejection of an offer solely based on narrow assets and income evaluations should be avoided. Pursuant to the IRS, Collection normally is withheld during the period an offer-in-compromise is pending, unless it is determined that the offer is a delaying tactic and collection is in jeopardy. The Conference Report explanation notes (page 288) that under the Senate amendment to H.R. 2676 the IRS is: "required to consider the facts and circumstances of a particular taxpayer’s case in determining whether the national and local schedules are inadequate for that particular taxpayer. If the facts indicate that the use of scheduled allowances would be inadequate under the circumstances, the taxpayer is not limited by the national or local allowances." The Conference Report also notes (page 288) the following: Liberal acceptance policy.—The Senate amendment provides that the IRS will adopt a liberal acceptance policy for offers-in-compromise to provide an incentive for taxpayers to continue to file tax returns and continue to pay their taxes. The Conference Agreement also states (p 289) that the Secretary is authorized to prescribe guidelines for the IRS to determine whether an offer-in-compromise is adequate and "should be accepted to resolve a dispute." The Conferees expect that the present regulations will be expanded so as to permit the IRS, in certain circumstances, to consider: additional factors (i.e., factors other than doubt as to liability or collectibility) in determining whether to compromise the income tax liabilities of individual taxpayers. For example, the conferees anticipate that the IRS will take into account factors such as equity, hardship, and public policy where a compromise of an individual taxpayer’s income tax liability would promote effective tax administration. The conferees anticipate that, among other situations, the IRS may utilize this new authority to resolve long-standing cases by forgoing penalties and interest which have accumulated as a result of delay in determining the taxpayer’s liability. The conferees believe that the ability to compromise tax liability and to make payments of tax liability by installment enhances taxpayer compliance. In addition, the conferees believe that the IRS should be flexible in finding ways to work with taxpayers who are sincerely trying to meet their obligations and remain in the tax system. Accordingly, the conferees believe that the IRS should make it easier for taxpayers to enter into offer-in-compromise agreements, and should do more to educate the taxpaying public about the availability of such agreements. The Conference Report states that its provisions are generally effective for offers-in-compromise submitted after the date of enactment. The date of enactment is June 22, 1998. The IRS has published its comments on section 3462 of IRS Restructuring and Reform Act of 1998, as follows: Section 3462 A. Provision covered: R.R.A. § 3462. Offers-In-Compromise. I.R.C. §§ 6159, 6331, and 7122 B. Background: Section 7122 of the Internal Revenue Code generally provides that the Service may compromise any case arising under the internal revenue laws, prior to referring that case to the Department of Justice for defense or prosecution. Current regulations provide two bases for compromise: doubt as to collectibility and doubt as to liability. The internal revenue manual provides guidance for determining an adequate doubt as to collectibility offer. Congress believes that the Service should be more flexible in working with taxpayers who are sincerely trying to satisfy their tax obligations and, thus, the Service should make it easier for taxpayers to enter into offers-in-compromise. The tax writing committees have indicated that taxpayer compliance is enhanced by the ability to compromise and to make payments via an installment agreement. C. Change(s): The following changes have been made with regard to the offer in compromise procedures:
Impact of New Policy and Law
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