- 3 -
* * * * * * *
(j) I/we understand that I/we remain responsible for
the full amount of the tax liability, unless and
until the IRS accepts the offer in writing and
I/we have met all the terms and conditions of the
offer. The IRS will not remove the original
amount of the tax liability from its records until
I/we have met all the terms of the offer.
* * * * * * *
(o) If I/we fail to meet any of the terms and
conditions of the offer and the offer defaults,
then the IRS may:
• immediately file suit to collect the entire
unpaid balance of the offer
• immediately file suit to collect an amount
equal to the original amount of the tax
liability as liquidating damages, minus any
payment already received under the terms of
this offer
• disregard the amount of the offer and apply all
amounts already paid under the offer against
the original amount of the tax liability
• file suit or levy to collect the original
amount of the tax liability, without further
notice of any kind.
Respondent accepted petitioner’s OIC by a letter dated
February 25, 2000. That letter stated, in relevant part:
“Please note that the conditions of the offer require you to file
and pay all required taxes for five tax years or the period of
time payments are being made on the offer, whichever is longer.”
The letter also reiterated the language above from Item 8,
paragraph (o) of the OIC.
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Last modified: May 25, 2011