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OIC 126: Appellate Rights
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…
OIC 127: Levy Affected by OIC
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…
OIC 128: OIC Affects an Installment Agreement
Installment Agreements Affected by OIC. Is a taxpayer required to continue making installment agreement payments if the taxpayer plans on filing an Offer in Compromise? Yes, is the simple answer because the Offer in Compromise application has not yet been submitted and has not yet been approved for processing by the IRS. …
OIC 130: Criminal Restitution Issues
Criminal Restitution Issues. Taxpayers may submit an Offer in Compromise application to resolve criminal penalties. The Secretary of the Treasury may compromise any criminal liability arising under the internal revenue laws prior to the reference to the Department of Justice for prosecution or defense. 26 U.S.C. § 7122(a). An agreement…
OIC 131: Miscellaneous OIC Issues – Part 1
Miscellaneous Offer in Compromise Issues – Part 1. Attorneys are authorized to represent taxpayers before the IRS on collection matters, including an Offer in Compromise. IRM § 5.8.4.25(6) (05-10-2013). Taxpayers have a set of fundamental rights they should be aware of when dealing with the IRS. For more information, go…
OIC 132: Miscellaneous OIC Issues – Part 2
Miscellaneous Offer in Compromise Issues – Part 2. Attorneys are authorized to represent taxpayers before the IRS on collection matters, including an Offer in Compromise. IRM § 5.8.4.25(6) (05-10-2013). Taxpayers have a set of fundamental rights they should be aware of when dealing with the IRS. For more information, go…