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or return information for verification
of such liability; and
(ii) the taxpayer shall not be
required to provide a financial
statement.
(d) Administrative Review.–-The Secretary shall
establish procedures--
(1) for an independent administrative review
of any rejection of a proposed offer-in-compromise
or installment agreement made by a taxpayer under
this section or section 6159 before such rejection
is communicated to the taxpayer; and
(2) which allow a taxpayer to appeal any
rejection of such offer or agreement to the
Internal Revenue Service Office of Appeals.
Regulations adopted pursuant to section 7122 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. 301.7122-1, Proced. & Admin.
Regs. With respect to the third ground, paragraph (b)(3)(i) of
the regulation allows for a compromise to be entered into to
promote effective tax administration where collection in full
could be achieved but would cause economic hardship. Paragraph
(c)(3)(i) sets forth factors that would support (but are not
conclusive of) a finding of economic hardship. With respect to
the third ground, those regulations state:
(3) Compromises to promote effective tax
administration.–-(i) Factors supporting (but not
conclusive of) a determination that collection would
cause economic hardship within the meaning of paragraph
(b)(3)(i) of this section include, but are not limited
to--
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