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With regard to our prior opinion herein, respondent
3(...continued)
taxpayer pursuant to the judgment in the
proceeding (determined without regard to
interest) is equal to or less than the
liability of the taxpayer which would have
been so determined if the United States had
accepted a qualified offer of the party under
subsection (g).
* * * * * * *
(g) Qualified Offer.--For purposes of subsection
(c)(4)--
(1) In general.--The term “qualified offer” means
a written offer which--
(A) is made by the taxpayer to the United
States during the qualified offer period;
(B) specifies the offered amount of the
taxpayer’s liability (determined without regard to
interest);
(C) is designated at the time it is made as a
qualified offer for purposes of this section; and
(D) remains open during the period beginning
on the date it is made and ending on the earliest
of the date the offer is rejected, the date the
trial begins, or the 90th day after the date the
offer is made.
(2) Qualified offer period.--For purposes of this
subsection, the term “qualified offer period” means the
period--
(A) beginning on the date on which the 1st
letter of proposed deficiency which allows the
taxpayer an opportunity for administrative review
in the Internal Revenue Service Office of Appeals
is sent, and
(B) ending on the date which is 30 days
before the date the case is first set for trial.
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