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August 25, 2005
Fogel on The "Effective Tax Administration" Offer in Compromise
David M. Fogel (McDonough Holland & Allen, Sacramento) has published The "Effective Tax Administration" Offer in Compromise, also available on the Tax Analysts web site as Doc 2005-17723, 2005 TNT 163-34. Here is the abstract:
Despite a provision of the IRS Restructuring and Reform Act of 1998 that authorized the IRS to accept offers in compromise based on equity, hardship, and public policy to promote effective tax administration, the IRS has not widely embraced the concept. Less than 1% of the total offers that the IRS has accepted are "effective tax administration" offers. What are the conditions for accepting those offers? Why is the IRS so reluctant to accept them? Have the courts decided any cases involving that type of offer? This article explores those issues and others.
August 25, 2005 in Scholarship, Tax Analysts | Permalink
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The tax law has long allowed the IRS to compromise tax liabilities when there is doubt about whether am amount... [Read More]
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