Wednesday, June 4, 2008

Public access to accepted Offers in Compromise

Return information may be disclosed to the general public to the extent necessary to permit inspection of any accepted offer-in-compromise (Code Sec. 6103(k)(1); Reg. §301.7122-1(j)). Notably, neither the Code nor the Regulations define "to the extent necessary." However, the Internal Revenue Manual specifies that the inspection file of accepted offers will be maintained and available for public examination in the office of the district director having jurisdiction:

(1) for a period of one year; and

(2) each accepted offer will have a copy of the relevant Form 7249, Offer Acceptance Report, available for review (Internal Revenue Manual, 09-01-2005.

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