Ronald W. Oman - Page 12

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                    (2) A decision to reject an offer for public                      
               policy reason(s) should be based on the fact that                      
               public reaction to the acceptance of the offer could be                
               so negative as to diminish future voluntary compliance                 
               by the general public.  Decisions to reject offers for                 
               this reason should be rare.                                            
               Example: Below are some examples of situations that may                
               warrant rejection based on a public policy decision.                   
               The taxpayer has openly encouraged others to refuse to                 
               comply with the tax laws.                                              
               Suspicion that the financial benefits of a criminal                    
               activity are concealed or the criminal activity is                     
               continuing.                                                            
                    (3) An offer will not be rejected for public                      
               policy grounds solely because:                                         
                    (a) It would generate considerable public                         
               interest, some of it critical.                                         
                    (b) A taxpayer was criminally prosecuted for tax                  
               or non-tax violation.                                                  
                    (4) The rejection narrative should discuss the                    
               specific public policy issues.                                         
                    (5) Rejections of this type require the approval                  
               of the SB/SE Compliance Area Director in the field or                  
               SB/SE Compliance Services Field Director for COIC.                     
               [Emphasis omitted.]                                                    
          Policy statement P-5-89 does not specifically reference                     
          “egregious past non-compliance”, but appears to provide that in             
          some cases it may be a legitimate basis for rejecting an offer              
          that exceeds the reasonable collection potential.  However, IRM             
          sec. 5.8.7.6.1 provides that respondent should discuss and                  
          document the specific public policy issues relevant to the case             
          in the rejection narrative.  Respondent did not reference either            






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