- 9 - IRM, sec. 57(10)9.1(1)-(2) (Feb. 26, 1992). An offer is unprocessable if: (1) The taxpayer is not identified; (2) the liabilities to be compromised are not identified; (3) no amount is offered; (4) appropriate signatures are not present; (5) financial statement is not provided; (6) the offer does not reasonably reflect net equity in assets on Forms 433-A and 433-B and amounts recoverable from future income sources, as reflected on financial statements;6 (7) an obsolete Form 656 is used; or (8) the taxpayer alters the terms on Form 656. IRM, sec. 57(10)9.1(3) (Feb. 26, 1992). 1. Petitioners’ First Offer in Compromise On September 19, 1994, petitioners submitted Form 656, offering to compromise their 1993 tax liability for $5,000 on the ground of doubt as to collectibility. Petitioners submitted Forms 433-A and 433-B in support of their offer. By letter dated December 20, 1994, respondent advised 6 However, the Internal Revenue Manual cautions: judgment should be exercised when deciding whether to return an offer as unprocessable for this reason alone. It may be desirable to receive an offer into inventory which does not technically meet this criterion. This would apply if the amount offered is close enough to the sum of net equity from Forms 433-A and 433-B, and amounts recoverable from future income sources that successful negotiation with the taxpayer could be pursued. IRM, sec. 57(10)9.1(3)(f) (Feb. 26, 1992).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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