Course Tag: Independent Administrative Review


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 § (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…