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A qualified offer is defined in section 7430(g)(1) as a
written offer which:
(A) is made by the taxpayer to the United States
during the qualified offer period;
(B) specifies the offered amount of the taxpayer’s
liability (determined without regard to interest);
(C) is designated at the time it is made as a
qualified offer for purposes of this section; and
(D) remains open during the period beginning on
the date it is made and ending on the earliest of the
date the offer is rejected, the date the trial begins,
or the 90th day after the date the offer is made.
Respondent argues that petitioner’s offers were not qualified
offers because they were not made during the qualified offer
period and because they do not specify the amount of petitioner’s
liability.8
1. Qualified Offer Period
Respondent argues that petitioner’s offers could not be a
qualified offer because they were not made within the qualified
offer period. The qualified offer period begins on the date
respondent informs the taxpayer of a proposed deficiency and
“ending on the date which is 30 days before the date the case is
first set for trial.” Sec. 7430(g). Respondent interprets this
8 Respondent does not argue, and thus we do not consider,
that petitioner’s offer not be considered a qualified offer
because petitioner failed to provide respondent with the
substantiation and legal and factual arguments necessary for
informed consideration of petitioner’s claim for relief as
required by sec. 301.7430-7(c)(4), Proced. & Admin. Regs.
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Last modified: November 10, 2007