James Weldon Aaron - Page 13

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          confidence that the tax laws are being administered in a fair and           
          equitable manner.  A taxpayer proposing a compromise on the basis           
          of effective tax administration will be expected to demonstrate             
          circumstances that justify a compromise even though a similarly             
          situated taxpayer may have paid his liability in full.  Id.                 
          Examples of where a compromise is allowed for purposes of public            
          policy and equity include:  (1) A taxpayer who was hospitalized             
          regularly for a number of years and was unable to manage his                
          financial affairs incurs significant tax liabilities, penalties             
          and interest; and (2) a taxpayer learns at audit that he received           
          erroneous advice from the IRS and, as a result, is facing                   
          additional taxes, penalties, and additions to tax.  Speltz v.               
          Commissioner, supra at 173; sec. 301.7122-1(c)(3)(C)(iv), Proced.           
          & Admin. Regs.                                                              
               Petitioner has identified no public policy or equity                   
          considerations that would justify a compromise on the basis of              
          effective tax administration.  The Government may request                   
          additional information from a taxpayer after an OIC is accepted             
          for processing.  Sec. 301.7122-1(d)(2), Proced. & Admin. Regs.              
          The taxpayer’s refusal to provide the requested information                 
          within a reasonable time is grounds for returning the OIC.  Id.             
          Petitioner failed to mention the paralegal business in his OIC.             
          When the offer specialist learned of the existence of this                  
          business, she was entitled to request additional information,               






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