- Instructor: Attorney Bob Schaller
- Lectures: 5
- Quizzes: 1
Levy Affected by OIC.
Taxpayers are not protected from the IRS collection apparatus while contemplating or completing an Offer in Compromise application. Similarly, taxpayers are not automatically protected from levy by submitting an Offer in Compromise application. “Submission of an Offer in Compromise does not automatically stay collection of an account. If there is any indication that the filing of an Offer in Compromise was solely for the purpose of delaying collection of the liability or that delay would jeopardize the Government’s interest, immediate steps should be taken to collect the unpaid liability. However, if it is determined that the offer merits consideration and that the Government’s interests would not be jeopardized by delay, collection action will be withheld pending consideration of the Offer in Compromise.” Policy Statement 5-97, IRM § 1.2.14.1.16 (07-10-1959).
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Overview How a Levy is Affected by an OIC
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Unprocessable Offers
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Processable Offers - Outstanding Levy
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Processable Offers - Initiating New Levy
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Revised Offer Following Rejection
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Quiz
Reviews
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Tax Law
This course teaches tax professionals that taxpayers are not protected from the IRS collection apparatus while contemplating or completing an Offer in Compromise application. Similarly, taxpayers are not automatically protected from levy by submitting an Offer in Compromise application. However, if it is determined that the offer merits consideration and that the Government's interests would not be jeopardized by delay, collection action will be withheld pending consideration of the Offer in Compromise.
