- 12 - (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 eitherPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011