Course Category: Accepting an Offer

“Accepting” a Pending Offer by the IRS. The decision whether to “accept” an offer to compromise is within the IRS’ discretion and must be based upon consideration of all the facts and circumstances.  26 C.F.R. § 301.7122-1(c)(1); Johnson v. Commission of Internal Revenue, 136 T.C. 475, 485 (2011); Christopher Cross, Inc.…