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Wednesday, August 15, 2012
Counsel opinion for offers-in-compromise
COMREP ¶ 71,221.01 Increase in threshold requirement for Chief Counsel opinion on compromise offers. (Taxpayer Bill of Rights 2, , PL 104-168, 7/30/96)
Reasons for Change.
The Committee believes that the $500 threshold amount requiring a written opinion from the IRS Chief Counsel slows the approval process for most offers-in-compromise and is unnecessarily low.
Explanation of Provision.
The bill increases from $500 to $50,000 the amount requiring a written opinion from the Office of Chief Counsel. Compromises below the $50,000 threshold must be subject to continuing quality review by the IRS.
The provision is effective on the date of enactment.