- Instructor: Attorney Bob Schaller
- Lectures: 6
- Quizzes: 1
“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. v. US, 363 F.Supp.2d 855, 857 (E.D. La. 2004). In keeping with IRS Policy Statement P-5-100, IRM § 1.2.14.1.17 (01-30-1992), an offer will only be accepted if it is determined to be in the best interest of both the taxpayer and the IRS. Rev. Proc. 2003-71, § 6.03. The IRS may take into account public policy and tax administration concerns in determining whether an offer to compromise is acceptable. Rev. Proc. 2003-71, § 6.03.
Curriculum
- 7 Sections
- 6 Lessons
- Lifetime
Expand all sectionsCollapse all sections
- Video Overview1
- Overview of the IRS' Decision to Accept a Pending Offer1
- IRS Acceptance Policy1
- IRS Must Accept Offer in Writing1
- Acceptance Conclusively Settles All Liability1
- Offer Rescission Considerations1
- Quiz1
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