OIC 121: Rejecting a Pending Offer
“Rejecting” a Pending Offer. The IRS can “reject” a processable Offer in Compromise application for many reasons. The IRS defines “reject” as a non-acceptance recommendation of any OIC offer that includes appellate rights. IRM § 5.8.7.1.6(1) (12-20-2018). The rejection of an application closes the Offer in Compromise application review process. …
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…
IA 112: Appellate Review
Appellate Review. The Tax Code requires the IRS to conduct an “independent administrative review” before the rejection of an installment agreement is communicated to the taxpayer. 26 U.S.C. § 7122(e). Although the intention to recommend rejection should be relayed to the taxpayer, actual rejection of a proposed agreement must not be…