- 8 - after petitioners’ 1993 liability was fully satisfied. See infra “E”. At this time we are closing your case out of the Problems Resolution Program and apologize for any inconvenience we may have caused you. Petitioners’ 1993 account remained in uncollectible status until July 11, 1997. D. Petitioners’ Efforts To Compromise Their 1993 Tax Liability By virtue of section 7122(a), the Commissioner is authorized to compromise a taxpayer’s tax liability. Pursuant to that authority, the Commissioner has published directives regarding offers in compromise.5 See Internal Revenue Manual (IRM), sec. 57(10)0 (Feb. 26, 1992) et seq. Form 656, Offer in Compromise, is the form that respondent has designed for use by a taxpayer who wishes to submit an offer in compromise. When an offer in compromise is received from a taxpayer, a determination is made by an offer technician whether the offer is “processable”. IRM, sec. 57(10)9.1(1) (Feb. 26, 1992). An offer that is processable is assigned to a collection officer, typically a revenue officer, for investigation and evaluation. An offer that is “unprocessable” is returned to the taxpayer. 5 We note that the enactment of sec. 7122(c), relating to the evaluation of offers in compromise, because it applies to offers in compromise submitted after July 22, 1998, does not apply in this case. The same is true of the temporary regulations published thereunder, which are applicable to offers in compromise submitted on or after July 21, 1999, through July 19, 2002. See sec. 301.7122-1T(j), Temporary Proced. & Admin. Regs., 64 Fed. Reg. 39027 (July 21, 1999).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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