David L. Samuel - Page 15




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          to liability, doubt as to collectibility, and the promotion of              
          effective tax administration.  Sec. 301.7122-1(b), Proced. &                
          Admin. Regs.  Petitioner seeks a compromise based on doubt as to            
          collectibility.                                                             
               The Secretary may compromise a tax liability based on doubt            
          as to collectibility where the taxpayer’s assets and income are             
          less than the full amount of the liability.  Sec. 301.7122-                 
          1(b)(2), Proced. & Admin. Regs.  Generally, under the                       
          Commissioner’s administrative procedures, an offer-in-compromise            
          based on doubt as to collectibility will be acceptable only if it           
          reflects the taxpayer’s “reasonable collection potential”.  Rev.            
          Proc. 2003-71, sec. 4.02(2), 2003-2 C.B. 517.  Both parties                 
          appear to agree that petitioner’s reasonable collection potential           
          is substantially less than his tax liability which, as above                
          noted, stood at more than $773,368, as of January 1, 2005.  The             
          parties obviously disagree as to petitioner’s collection                    
          potential.                                                                  
               The IRS has developed guidelines and procedures for the                
          submission and evaluation of offers to compromise under section             
          7122.  Rev. Proc. 2003-71, supra.  In furtherance thereof, the              
          Internal Revenue Manual (IRM) contains extensive guidelines for             
          evaluating offers-in-compromise.  1 Administration, Internal                










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