- 7 - Compromise of Tax Liabilities Petitioner contends that the first call resulted in an agreement under which he would be required to pay a total amount that was less than he owed. We have found as a fact that he believed that after making the payments for 36 months, he would owe nothing more with respect to his tax liabilities. Respondent contends that an installment agreement, not a compromise, was made during the first call. Respondent contends that, according to guidelines set forth in the Internal Revenue Manual, amounts that were accrued but unassessed at the time of the first call, such as interest and penalties, would not be covered by the installment payments, and would remain due even after all of the installment payments had been made. It is well settled that section 7122 and the regulations thereunder provide the exclusive method of effectuating a valid compromise of assessed tax liabilities. Ringgold v. Commissioner, T.C. Memo. 2003-199; see also Botany Worsted Mills v. United States, 278 U.S. 282, 288-89 (1929); Laurins v. Commissioner, 889 F.2d 910 (9th Cir. 1989), affg. Norman v. Commissioner, T.C. Memo. 1987-265. After evaluating the requirements of section 7122 and the regulations thereunder, we find that petitioner and the ACS employee did not enter into a binding agreement to compromise petitioners’ liabilities.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011