Alvin Brown & Associates is a tax law firm specializing in IRS issues and problems in 50 states and abroad. 888-712-7690 Fax: (888) 832 8828 ab@irstaxattorney.com 575 Madison Ave., 8th Floor New York, NY 10022 www.irstaxattlorney.com www.irsconsultingservices.com
Friday, March 25, 2011
The Department of Treasury has just propose some tax law changes that include changes in the offer in compromise law
REVISE OFFER-IN-COMPROMISE APPLICATION RULES
Current Law
Current law provides that the Internal Revenue Service (IRS) may compromise any civil or
criminal case arising under the internal revenue laws prior to a reference to the Department of
Justice for prosecution or defense. In 2006, a new provision was enacted to require taxpayers to
make certain nonrefundable payments with any initial offer-in-compromise of a tax case. The
new provision requires taxpayers making a lump-sum offer-in-compromise to include a
nonrefundable payment of 20 percent of the lump-sum with the initial offer. In the case of an
offer-in-compromise involving periodic payments, the initial offer must be accompanied by a
nonrefundable payment of the first installment that would be due if the offer were accepted.
Reasons for Change
Requiring nonrefundable payments with an offer-in-compromise may substantially reduce access
to the offer-in-compromise program. The offer-in-compromise program is designed to settle
cases in which taxpayers have demonstrated an inability to pay the full amount of a tax liability.
The program allows the IRS to collect the portion of a tax liability that for offers-in-compromise submitted after the date of enactment
ab@irstaxattorney.com 888-712-7690
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