Robert and Grace Bergevin - Page 17




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                         (1) for an independent administrative review                 
                    of any rejection of a proposed offer-in-compromise                
                    or installment agreement made by a taxpayer under                 
                    this section or section 6159 before such rejection                
                    is communicated to the taxpayer; and                              
                         (2) which allow a taxpayer to appeal any                     
                    rejection of such offer or agreement to the                       
                    Internal Revenue Service Office of Appeals.                       
               Regulations adopted pursuant to section 7122 set forth three           
          grounds for the compromise of a liability:  (1) Doubt as to                 
          liability; (2) doubt as to collectibility; or (3) promotion of              
          effective tax administration.  Sec. 301.7122-1, Proced. & Admin.            
          Regs.  With respect to the third ground, paragraph (b)(3)(i) of             
          the regulation allows for a compromise to be entered into to                
          promote effective tax administration where collection in full               
          could be achieved but would cause economic hardship.  Paragraph             
          (c)(3)(i) sets forth factors that would support (but are not                
          conclusive of) a finding of economic hardship.  With respect to             
          the third ground, those regulations state:                                  
                    (3) Compromises to promote effective tax                          
               administration.–-(i) Factors supporting (but not                       
               conclusive of) a determination that collection would                   
               cause economic hardship within the meaning of paragraph                
               (b)(3)(i) of this section include, but are not limited                 
               to--                                                                   
                         (A) Taxpayer is incapable of earning a living                
               because of a long term illness, medical condition, or                  
               disability, and it is reasonably foreseeable that                      
               taxpayer’s financial resources will be exhausted                       
               providing for care and support during the course of the                
               condition;                                                             
                         (B) Although taxpayer has certain monthly                    
               income, that income is exhausted each month in                         






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Last modified: March 27, 2008