James J. Crisan and Veronica L. Crisan - Page 8

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          abuse of discretion.  Section 7122(a) authorizes the Secretary to           
          compromise any civil case arising under the internal revenue                
          laws.  The regulations set forth three grounds for the compromise           
          of a liability:  (1) Doubt as to liability; (2) doubt as to                 
          collectibility; or (3) promotion of effective tax administration.           
          Sec. 301.7122-1T(b), Temporary Proced. & Admin. Regs., 64 Fed.              
          Reg. 39024 (July 21, 1999); see sec. 7122(c)(1).  Doubt as to               
          liability is not at issue in the instant case.                              
               The Secretary may compromise a liability on the ground of              
          doubt as to collectibility when “the taxpayer’s assets and income           
          are less than the full amount of the assessed liability”.  Sec.             
          301.7122-1T(b)(3)(i), Temporary Proced. & Admin. Regs., supra.              
          Additionally, the Secretary may compromise a liability on the               
          ground of “effective tax administration” when:  (1) Collection of           
          the full liability will create economic hardship; or (2)                    
          exceptional circumstances exist such that collection of the full            
          liability will be detrimental to voluntary compliance by                    
          taxpayers; and (3) compromise of the liability will not undermine           
          compliance by taxpayers with tax laws.  Sec. 301.7122-1T(b)(4),             
          Temporary Proced. & Admin. Regs., supra; see 2 Administration,              
          Internal Revenue Service (CCH), sec. 5.8.11.2, at 16,385-15                 
          (taxpayer’s liability may be eligible for compromise to promote             
          effective tax administration if not eligible for compromise based           








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