- 7 - applicable law and administrative procedures have been met, and consider “whether any proposed collection action balances the need for the efficient collection of taxes with the legitimate concern of the person [involved] that any collection action be no more intrusive than necessary.” Sec. 6330(c)(3)(C). Here, petitioners do not dispute that all administrative procedures have been met so the sole issue for our consideration is whether respondent’s rejection of petitioners’ OIC was an abuse of discretion. Section 7122 provides respondent with the authority to grant an offer in compromise as an alternative to collection action. Respondent grants an offer in compromise when there is a doubt as to the actual tax liability, doubt as to collectibility, or for other purposes relating to effective tax administration. Sec. 301.7122-1, Proced. & Admin. Regs.; 1 Administration, Internal Revenue Manual (CCH), sec. 5.8.1.1.2, at 16,253. The Appeals officer considered petitioners’ $2,000 offer on the grounds of “doubt as to collectibility” (as such term is used in the context of the foregoing reference to the regulations and the Internal Revenue Manual). The Appeals officer also took into consideration as a potential ground for compromise the promotion of effective tax administration. See sec. 301.7122-1(b)(3), Proced. & Admin. Regs. Respondent may accept an offer in compromise based on doubt as to collectibility when there arePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011