- Instructor: Attorney Bob Schaller
- Lectures: 17
- Quizzes: 1
Appellate Rights Relating to OICs.
This course discusses appellate rights in the Offer in Compromise context. Appellate rights are better understood when segregated into three issues: (1) appellate rights relating to a pre-rejection “independent administrative review”; (2) appellate rights following a collection due process determination (i.e. offer made as part of CDP hearing); and (3) appellate rights following a non-collection due process determination (i.e. stand-alone offer).
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Video Overview
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Overview of Appellate Rights
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Independent Administrative Review
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Appellate Rights Following Collection Due Process Determination
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Appellate Rights Following a Non-Collection Due Process Determination
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IRS Office of Appeals
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IRS Office of Appeals' Jurisdiction & Function
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Appealable & Non-Appealable Decisions
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30-Day Appeal Deadline
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Appeal Application Process
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Appellate Issues
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Appeals Referral Investigation
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Sustaining Offer Rejection
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Conference and Practice Requirements
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Re-Opening a Rejected Offer Previously Sustained on Appeal
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Taxpayer Compliance
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Ex Parte Communications are Prohibited
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Quiz
Reviews
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Tax Law
It is important for all tax professionals to know a taxpayer's appellate rights in the Offer in Compromise context. The course explained that appellate rights are better understood when segregated into three issues: (1) appellate rights relating to a pre-rejection “independent administrative review”; (2) appellate rights following a collection due process determination (i.e. offer made as part of CDP hearing); and (3) appellate rights following a non-collection due process determination (i.e. stand-alone offer).
Related Courses
Intro 103: Understanding the IRS Collection Process
Understanding the IRS Collection Process. https://youtu.be/qn3hMR9pjOk This course provides a brief overview of the IRS collection process. It does not provide strategies or exceptions to the rule. Later courses provide a greater explanation of these issues. The collection process starts after a taxpayer files a tax return without full payment…
OIC 101: IRS Authority to Eliminate Back-Taxes
IRS’ Authority, Motivation & Basis to Eliminate Back-Taxes. https://youtu.be/rwKeaiLO9xY An Offer in Compromise is an agreement between a taxpayer and the IRS that settles a tax liability for payment of less than the full amount owed. IRM § 5.8.1.2.1 (09-23-2008); Adamowicz v. US, 08-888C, Pg. 5 (D.C. Ct. Fed. Cl. 11/21/2011). …
OIC 102: Overview of the OIC Application Process
Overview of the Offer in Compromise Application Process. https://youtu.be/2FIA2Rv94cY This course focuses on a taxpayer’s ability to eliminate past-due federal income tax liability by establishing a repayment plan through the IRS “Offer in Compromise” program, which is commonly known as the “Fresh Start Initiative.” An overview is presented to help navigate…
OIC 103: Who Submits the OIC Application?
Who is the Proper Party to Submit the OIC Application? https://youtu.be/sW6KfFiK8wo Before filing a formal Offer in Compromise application, a taxpayer may request a meeting in the IRS office which would have jurisdiction over the offer to explore the possibility of compromising unpaid tax liability. 26 C.F.R. § 601.203(d). The Offer…
OIC 105: Is the OIC Offer “Processable?” – Part 1
Is the OIC Offer Submitted “Processable?” – Part 1. https://youtu.be/RGivexRiG_0 The IRS receives the taxpayer’s offer. The first step it takes is to determine if the submitted offer is “processable.” This issue is divided into two separate courses. Part 1 addresses issue relating to the taxpayer’s ability to fully pay…