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Contents
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- The purpose of the investigation is to
determine whether the amount offered
reasonably reflects collection potential.
- Service personnel determine an acceptable
offer amount and advise the taxpayer when an
increase in the offer amount is necessary.
- Assets will not be eliminated or
valued at zero dollars simply because we would
not take enforcement action against the asset,
even though the net result might be rejection
of the offer and reporting the case as
currently not collectible.
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- The offer should be reviewed to determine if
the amount of the offer is equal to the value
of the taxpayer's equity in assets that would
be legally and practically obtainable through
available collection procedures, both
administrative and judicial.
- An accurate determination of lien priority
issues must be made.
- An accurate determination of fraudulent
conveyance and/or transferee liability must be
made.
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- The Processability Letter should be sent to
the taxpayer and/or representative along with
Publications 1 and 594. The letter should be
issued within 14 days of receipt of Form 656.
- Initial contact with the taxpayer and/or
representative should be initiated within 45
days from the issuance of the Processability
Letter. This contact may be performed either
through telephone, correspondence, or by field
visitation.
- Procedures for follow-up actions as it
relates to perfection of the offer will
consist of the issuance of the Additional
Letter 2 and/or 3 allowing a 14 day deadline
to provide the requested documents. Within ten
(10) days of the expiration of the issuance of
the Additional Letter 2 and the taxpayer has
not responded, send the Additional Letter 3.
Provide another 14 days for the taxpayer to
respond and follow-up within ten (10) days.
- Follow-up actions during an offer
investigation are required within 15 days of
the taxpayer missing a deadline. Examples of
follow-up actions are:
- issuance of an Additional Information
Letter
- telephone contact
- recommendation to close the case
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- A flexible negotiation position should be
taken when trying to secure an acceptable
offer. Negotiation is not only limited to the
dollar amount but may also involve issues such
as:
- Terms of payments
- Benefits of earlier payment (i.e.
release of lien and reduced interest
accrual)
- Future earning potential
- Collateral Agreements
- NOTE:
- Any special circumstances of the
taxpayer that may warrant
consideration in determining
reasonable collection potential should
be evaluated before determining that
the amount offered by the taxpayer is
inadequate.
- In the event an offer is not an acceptable
resolution, negotiations should be directed
toward other case alternatives such as
- full payment
- installment agreement
- adjustment of the tax
- reporting uncollectible
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- An offer submitted based on doubt as to
collectibility must reasonably reflect
collection potential. The four components of
collectibility are:
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Component |
Definition |
Assets |
the amount collectible from the
taxpayer's net realizable equity |
Future income |
the amount collectible from the
taxpayer's income minus necessary living
expenses. For cash offers, it is the
amount that would be collected from the
taxpayer's income over a period of 48
months; for short term deferred offers, it
is the amount that would be collected over
a period of 60 months; and for deferred
payment offers, it is the amount that
would be collected over the life of the
statute |
Amount collectible from third parties |
transferee liability, Trust Fund
Recovery Penalty, etc. |
Assets or income that are available to
the taxpayer but not available to IRS |
the amount the taxpayer is reasonably
expected to raise from assets available to
him or her, but which are beyond the reach
of the Government. For example, assets
outside the country, or property owned as
a tenancy by the entirety. |
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- During the consideration of an offer in
compromise, a determination should be made
regarding the need to file a Notice of Federal
Tax Lien (NFTL) regardless of the tax
liability amount.
- The decision on when to file the Notice of
Federal Tax Lien should be based on the
individual case facts and circumstances.
- Notify the taxpayer of the decision to file
the NFTL prior to actual filing.
- If the lien is to be filed, follow the Due
Process procedures as outlined in the IRM.
- If the taxpayer appeals the filing of the
lien, continue processing the offer. An
agreement can be reached which can be
submitted to Appeals as a possible resolution.
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- The Service is bound by the payment terms of
the contract that we agreed to and the Service
cannot require payment of the offer amount in
different terms than agreed to in the
contract.
- Requests for discharge or subordination
received while an offer is pending or after
acceptance must be handled as follows:
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If after an offer has been accepted
and all payment terms have not been
completed and a request for discharge or
subordination is received... |
Then... |
and the taxpayer does intend to apply
the available proceeds received from the
discharge or subordination to the offered
amount. |
Deny the request |
and the taxpayer does intend to pay the
available proceeds towards the offered
amount. |
Investigate the discharge or
subordination and coordinate with Special
Procedures Function to apply the proceeds
to the offer amount. |
If while an offer is under
consideration... |
Then... |
the taxpayer submits a request for
discharge or subordination |
Work the request and allow the taxpayer
to submit the proceeds as an offer deposit
provided the taxpayer will sign Form 3040,
Authorization to Apply Offer in Compromise
Deposit to Liability, authorizing
application of the proceeds from the
discharge or subordination to be applied
to the tax liability should the offer be
rejected or withdrawn. Form 3040 should be
marked "Irrevocable." |
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- The taxpayer may amend the original
processable offer. Follow the table below to
identify whether the offer was amended
properly.
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If... |
Then... |
changes are made in the amount or terms
of the offer, tax periods, and/or class of
tax |
Prepare a new Form 656
marked "Amended" and secure the
taxpayer(s) signature(s) |
an amended offer is received |
1. Do not change the
original Automated Offer in Compromise (AOIC)
record |
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waiver date |
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IRS received date or; |
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district office received date |
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- NOTE:
- Making the above changes will
cause an error on the monthly OIC
Activity Report
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2. Add new tax periods from
an amended offer to the MFT screen. |
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3. Reflect the amended offer
waiver date on the MFT screen only for any
new tax periods added. |
- NOTE:
- If a taxpayer files an offer before
12-31-1999 and has to amend the offer after
this date, a new Form 656 can be submitted.
The original waiver will remain in effect.
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[5.8] 4.5 (02-04-2000)
Identifying Open Examinations, Underreporter
Cases, Amended or Duplicate Filed Returns
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- Prior to an acceptance of an offer, any
potential liabilities must be resolved.
- As an initial action upon receipt of an
offer investigation by the offer specialist,
review IDRS Command Codes, TXMODA, IMFOL,
BMFOL or AMDIS to identify potential audits,
open underreporter cases or unassessed amended
returns. If any potential liabilities are
identified, contact the assigned function to
resolve the issues.
- Double check these command codes immediately
before submitting an accepted offer for
approval to ensure no potential liability has
arisen while the investigation was conducted.
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If... |
Then... |
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an open Underreporter case exists (TC922
without a CP 2000 process code or TC 290
or 291), |
Contact the assigned
function and determine how best to resolve
the issue. The issue could be resolved by: |
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an amended or duplicate return is
identified by the presence of a TC 976 or
977 without a subsequent tax
increase/decrease, or |
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Expediting the case processing and
assessment of the liability so it can be
included in the offer |
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an open audit is identified by a Freeze
code -L and/or an AMDIS record |
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Surveying (closing) the open audit/underreporter
case without additional examination. |
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The taxpayer could withdraw the offer
and resubmit it at the close of the
pending examination. |
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- NOTE:
- Do not submit the offer for
acceptance until all potential
assessment/open audits are resolved.
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[5.8] 4.6 (02-04-2000)
Identifying TEFRA Partner with TEFRA Proceeding
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- When an offer in compromise based on doubt
as to collectibility is received from a Tax
Equity and Fiscal Responsibility Act (TEFRA)
partner associated with a TEFRA proceeding,
the Service is not in a position to compromise
with a partner until all partnership items for
all partners are settled for the years in
litigation.
- Collection will not work an offer in
compromise for one partner of a TEFRA
partnership until all partnership issues for
all partners have been resolved. To verify the
status of examination use IDRS CC AMDIS to
identify:
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If... |
Then... |
the Partnership Investor Control File (PICF)
code on AMDIS is a five (5), it indicates
that an investor with at least one open
TEFRA key case linkage exists. |
1. Advise the taxpayer that we cannot
consider an offer in compromise until all
TEFRA partnership issues have been
resolved.
2. Attempt to secure a withdrawal letter.
If the taxpayer refuses, then the case
must be rejected with appeal rights. |
The PICF code is seven (7), it indicates
there is a closed TEFRA examination. |
1. Verify with Examination that the
assessment was made.
2. Include the assessment in the offer. |
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[5.8] 4.7 (02-04-2000)
Innocent Spouse Claim and Offer Investigation
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- There will be situations in which a taxpayer
simultaneously files an innocent spouse claim
and an offer in compromise.
- Attempt a withdrawal of the offer and
forward the innocent spouse claim to
Examination.
- If the taxpayer does not withdraw the
offer, attempt to have the taxpayer amend
the doubt as to collectibility offer to a
doubt as to liability offer and forward
the offer and the claim to Examination.
- If the taxpayer does not withdraw or
amend the offer, forward the innocent
spouse claim to Examination and suspend
the offer investigation pending the
disposition of the claim.
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- It is possible that a taxpayer may submit an
offer based on doubt as to collectibility,
doubt as to liability, and effective tax
administration. These combination offers will
always be worked in Collection first.
- If all three categories are marked on Form
656 and the taxpayer does not meet the test
for doubt as to collectibility but exceptional
circumstances exist that allow consideration
under effective tax administration:
- Load the case onto AOIC
- Prepare a memorandum to Examination
through managerial channels with a
recommendation to request expedite
processing of the doubt as to liability
and/or effective tax administration
(detriment to voluntary compliance) issue.
- Attach a copy of Form 656.
- NOTE:
- Once Examination completes the
investigation, Collection will be
responsible for generating and issuing
all necessary closing documents.
- The Service is required to first determine
whether doubt as to collectibility and/or
doubt as to liability exist before we can
consider an effective tax administration
offer. (See IRM 5.8.11.2, Grounds for
Effective Tax Administration)
- If doubt as to liability is not indicated as
a consideration on Form 656, the liability
issue does not have to be considered prior to
initiating the effective tax administration
investigation.
- These offers will be loaded on AOIC and
should be closed when doubt as to
collectibility or effective tax administration
determination is finalized:
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If... |
Then... |
The offer is rejected and the taxpayer
does not appeal |
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Send the OIC, copy of the history, and
appropriate attachments to Examination
function. |
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Retain copy of offer, history, and all
other documents related to doubt as to
collectibility. |
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Add an AOIC history entry stating that
the case is being sent to Exam and close
the AOIC record. |
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Manually re-input TC 480 with
jurisdiction code 2 |
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Manually re-input CC STAUP on
appropriate periods to status 71. |
the rejection is appealed |
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Send the offer to Appeals before sending
it to Examination. |
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If the rejection is sustained by
Appeals, close the AOIC record and follow
the procedures where the taxpayer does not
appeal the rejection to manually re-input
TC 480, STAUP appropriate periods, and
forward the case to Examination. |
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Note in the AOIC history that the case
has been forwarded to Examination. |
The offer is recommended for acceptance
based on doubt as to collectibility. |
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Process the acceptance using normal
procedures. |
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It is not necessary to send any
information to the Examination Division. |
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It is not necessary to amend the offer
to remove the Doubt as to Liability
reference. |
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- When an offer is based in whole or in part
on doubt as to liability including Trust Fund
Recovery Penalty (TFRP) and the Appeals Office
has determined the liability or the case is
pending before the Appeals Office, the
district director will forward the offer to
Appeals for consideration.
- If an offer in compromise based on doubt as
to liability is pending in the Appeals Office,
the Appeals Office may call upon the district
director to conduct any investigation deemed
necessary to reach a conclusion on the merits
of the case. These investigations should be
conducted as expeditiously as possible.
- If an offer is submitted based only on doubt
as to collectibility and there is an open case
pending in Appeals:
- Defer investigation of the offer.
- Notify the Appeals Office and ask
whether there is any objection to
consideration of the offer.
- Appeals will respond within 30 days.
- The Appeals Office will inform
Collection of any objection by memorandum.
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If... |
Then... |
no objections by Appeals |
Collection will investigate
the offer. |
the offer is recommended for acceptance |
1. |
Notify the Appeals Office and request
the assessment of the liability. |
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2. |
Mail the acceptance letter once the
assessment is made. |
the offer is rejected |
Notify Appeals. |
- CAUTION:
- The filing of an offer does not stay the
running of the 90-day period set forth in a
deficiency notice.
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- If an offer is accepted from a corporation
to compromise trust fund taxes, there is no
basis for collection of any related TFRP
assessment. Therefore the amount that must be
offered to compromise a corporate employment
tax liability must include an amount equal to
what can be collected from the responsible
person(s) in addition to what can be collected
directly from the corporation.
- The statutory suspension on an offer
submitted on behalf of a business to
compromise employment tax will not extend the
time for assessing the TFRP against an
officer, employee, or other responsible
person.
- Before beginning the Corporate offer
investigation:
- Determine if the TFRP has been assessed.
- Complete the TFRP investigation
following locally established guidelines,
if it has not been completed. (
- NOTE:
- Assessment of the TFRP may be held
in abeyance pending the outcome of the
offer investigation.)
- Verify ASEDs and protect if expiration
is imminent
- Secure current Collection Information
Statements from all responsible persons
- If the corporate offer is accepted, follow
the chart below:
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If... |
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Then... |
a cash offer |
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notify the employee assigned
the TFRP assessments to request a zero
dollar adjustment and forward Form 3870 to
the TFRP unit at SCCB |
If... |
And the TFRP accounts
are in... |
Then... |
a corporate deferred payment offer |
the same D.O. as the
corporate offer or in another D.O.
which is serviced by the same service
center and there are no other
outstanding IMF liabilities for the TFRP
TIN |
1. Mail the TFRP TDAs to the Service
Center offer unit (DOAO) 8500.) Attach the
TDAs to the Form 3870.
2. Annotate in red on the Form 3870 "TSIGN
TFRP accounts to 8500." |
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the same D.O. as the
corporate offer or in another D.O.
which is serviced by the same service
center and there are other
outstanding IMF liabilities |
Annotate in red on the Form 3870,
"Open Control Base" with literal
"Corp OIC Pen" . |
If... |
And the TFRP accounts
are in... |
Then... |
a corporate deferred payment offer |
another D.O. which is
serviced by a different service
center than the D.O. with the corporate
offer and there are no other
outstanding IMF liabilities
another D.O. which is serviced by a
different service center than the
D.O. with the corporate offer and there are
other outstanding IMF liabilities |
1. Request transfer of the TFRP TDAs
from the other D.O. and attach to the Form
3870. Upon receipt mail to the S.C.
2. Annotate in red on the Form 3870,
"TSIGN TFRP accounts to 8500."
Annotate in red on the Form 3870,
"Open Control Base" with literal
"Corp OIC Pen" . |
- The sum of the amount to be paid on the
Corporate offer and payments made on related
TFRP assessments may exceed the total
Corporate employment tax liability (for the
same tax periods). If this situation exists:
- Have the Corporate officer(s) sign an
irrevocable request to transfer their TFRP
payments to the related Corporate
liabilities
- Request the credit transfers per the
above requests
- Secure full payment of the balance due
from the Corporation
- Request a withdrawal of the Offer in
Compromise
- If an offer is accepted for a corporation
and no Trust Fund Recovery assessments
have been made, do the following:
- Secure Form 2751, Proposed Assessment of
Trust Fund Recovery Penalty from each
responsible person as a condition of the
offer acceptance.
- Secure Form 2750, Extending the ASED to
a date 2 years beyond the anticipated
completion date of all terms and
conditions of the offer; the applicable
compliance provision; or any related
collateral agreements, whichever is the
latest date.
- NOTE:
- No extension is necessary if a
decision has been made that the TFRP
would be uncollectible if assessed.
- Forward the Forms 2750, 2751 and the
complete TFRP investigation file to the
service center with the accepted offer
file. If there is a default, this file
will be returned to the district office
for processing and assessment of the TFRP.
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[5.8] 4.11 (02-04-2000)
Offers Related to Personal Liability for Excise
Tax
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- The following information pertains to
receipt of an offer from a business which
includes liabilities for unpaid fuel excise
tax which is subject to personal liability
provisions of IRC 4103.
- An acceptable offer must represent the
maximum collection potential for the business
and all persons who would be responsible for
the Personal Liability for Excise Tax (PLET).
The amount accepted from the business must
include an amount equal to what can be
collected from the responsible person(s) in
addition to what can be collected directly
from the corporation.
- If an offer in compromise is accepted from
the business and no PLET has been assessed,
there is no remaining basis for the assertion
of the PLET liability on the part of the
related taxpayers. If there are existing PLET
assessments at the time the offer is accepted
from a business, the Service may collect any
unpaid tax from the responsible persons to the
extent the tax was not paid by the business.
- Verify the correct ASED for potential
Personal Liability for Excise Tax assessments.
The ASED for the business will not apply to
the assertion of the Personal Liability for
Excise Tax.
- If an offer is to be accepted for a business
and there are no Personal Liability for Excise
Tax assessments, do the following:
- Secure a Form 9490, Waiver Extending
Statutory Period for Assessment of
Personal Liability for Excise Tax from
each responsible person as a condition of
the offer acceptance unless the PLET
cannot be collected from that person.
- Extend the assessment statute 2 years
beyond the anticipated completion date of
all terms and conditions of the offer;
including the applicable compliance
provision; and any related collateral
agreements.
- Assess the tax if a Form 9490 cannot be
obtained from responsible individuals.
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- The amount that must be offered to
compromise a partnership tax liability must
include maximum collection potential for the
partnership and all general partners. Secure
Collection Information Statements from the
partnership and all partners before beginning
your analysis.
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- In order to qualify for streamlined
processing, the processable offer must meet
the following criteria:
- The liability must be for personal
income tax, penalty assessment, or
employment tax owed by out-of-business
sole proprietorships,
- The aggregate liability must be $50,000
or less (including accrued penalty and
interest),
- The taxpayer(s) must be wage earner(s)
or self-employed with no employees (i.e.,
no current 941 filing requirement), and
- Real property owned must be limited to
personal residence only.
- Follow IRM 5.8.4.2.1, Initial Contact and
Follow-up Action Timeframes.
- While awaiting the reply, complete the case
building actions listed below. Query the
following IDRS or CFOL command codes:
- IRPTRO--obtain online IRP information
for the last three years
- AMDIS--If open audit indicators, contact
Exam Division to resolve
- UNLCER--check for co-obligor when debts
include TFRP
- RTVUE--note AGI for the last three
years. Verify income and expenses
reflected on the CIS (See 5.2 for more
details)
- MFTRAX--order for all periods included
on the offer for attachment to Form 7249
(order only if you believe the MFTRA will
still be current at the time the offer is
accepted)
- If the taxpayer fails to respond to the
Additional Letter 3, follow the procedures
under IRM 4.14, Return Procedures for
Streamline Offer Investigations.
- Conduct research of motor vehicle
information and real property records to
determine property ownership. Search the
external (DMV, REDI check) and internal
locator sources (including CFOL and other IDRS
command codes) to verify financial information
submitted by taxpayers.
- No field calls will be made to complete the
evaluation of streamlined offers. Complete
internal and external locator sources to
evaluate the offer. If locator sources are not
available and property ownership cannot be
determined using CFOL and other IDRS command
codes, the taxpayers should be contacted to
provide information to value and confirm
ownership of the assets., i.e., appraisals,
pictures of assets, comparable sales, etc.
- Upon receipt of the response to the document
request, analyze all information received and
verify the CIS data. Complete the Asset/Equity
Table (AET) and Income/Expense Table (IET) to
calculate the required minimum offer amount
(Exhibits 4-1 and 4-2). Contact the taxpayer
by phone to secure any additional information
needed to reach a decision regarding the
offer. Follow-up with the Additional
Information Letter 3, if applicable.
- If the offer is acceptable:
- Complete the OIC Recommendation Report
(Exhibit 4-3 ). ICS districts should use
the Offer Recommendation Sheet, Form 658,
available on the ICS macros. Attach the
AET and IET to the report.
- Prepare From 7249 and the acceptance
letter.
- If the offer must be increased:
- Contact the taxpayer by phone to advise
of the minimum amount that will be
recommended for acceptance. Review your
calculations with the taxpayer and upon
request, send the AET and IET to the
taxpayer for review. If you are unable to
contact the taxpayer by phone, send the
tables and Form 656 with an "increase
amount letter" (Exhibit). Set a
reasonable deadline for the taxpayer to
amend the offer. Explain the independent
review and appeal process.
- If the taxpayer cannot or will not
increase the offer to the minimum amount,
complete the OIC Recommendation Report,
Form 1271, and generate the AOIC rejection
letter. Route through your manager for
independent review. Do not sign or date
the rejection letter.
- Follow IRM section 7.5 when the case is
received from the independent reviewer. If
there is a deposit, explain the merits of
having any deposit made with the offer applied
to the outstanding liability. If you cannot
contact the taxpayer by phone, send a letter
advising of your findings.
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[5.8] 4.14 (02-04-2000)
Return Procedures for Streamline Offer
Investigations
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- The offer will be returned to the taxpayer
without appeal rights. See IRM 7.4.1.
- In returned cases, complete the following
steps:
- Update the MFT screen with the current
balance tax, penalty, and interest for
each tax period identified on Form 656 to
ensure accuracy.
- Generate Form 1271 on AOIC
- Prepare Form 658, OIC Recommendation
Report (on ICS) and summarize the
following: The reason the offer is being
returned, Information concerning the
disposition of any deposit, and Case
resolution actions initiated or a
recommendation for resolution.
- Generate the Return Letter on AOIC which
should show the reason(s) for the return.
- The appropriate delegated official(s)
should sign and date Form 1271 and sign
but not date the Return Letter. Attach the
original Form 658 to the Return Letter and
retain a copy in the case file.
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- The case file should be forwarded to the
independent reviewer only if the reason for
the return was due to the taxpayer's failure
to provide financial information.
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[5.8] 4.16 (02-04-2000)
Case Closing Actions for Returned Streamlined
Offers
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- Annotate "returned" in the upper
portion of Form 656. The offer specialist or
examiner should initial the copy providing the
date the offer was returned to the taxpayer.
- Close the case on AOIC using disposition
code 10.
- The closed file should be retained in the
district and must include copies following
documents:
- Return letter
- Form 656
- Form 1271
- Form 658
- History sheets related to the offer.
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Exhibit [5.8] 4-1 (02-04-2000)
Asset/Equity Table (AET)
NAME_____ |
EIN/SSN_____ |
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Exhibit [5.8] 4-1 (02-04-2000)
Asset/Equity Table (AET)
ASSET/EQUITY
TABLE (AET) |
ASSETS |
Fair
Market
Value |
Quick
Sale
Value |
Encumbrances
or
Exemptions |
Net
Realizable
Equity |
Cash/Bank Account(s) |
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Offer Deposit |
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Loan Value Life Insurance |
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Pensions |
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Real Estate |
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Furniture/Personal Effects* |
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Vehicles |
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Accounts Receivable |
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Tools and/or Equipment** |
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Present or Installment Value
(see Income and Expense sheet attached) |
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TOTAL
MINIMUM OFFER |
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Exhibit [5.8] 4-1 (02-04-2000)
Asset/Equity Table (AET)
* |
IRC 6334(a)(2) allows an exemption of
$6,360 for fuel, provisions, furniture and
personal effects. |
** |
IRC 6334(a)(3) allows an exemption of
$3,180 for tools of the trade. |
REMARKS: |
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Exhibit [5.8] 4-2 (02-04-2000)
Income/Expense Table (IET)
INCOME/EXPENSE
TABLE (IET) |
The Internal Revenue Service
uses established National and Local
standards for necessary living expenses
when considering Offers In Compromise.
Only necessary living expenses will be
allowed. Other expenses such as charitable
contributions, education, credit cards,
and voluntary retirement allotments are
generally not considered as necessary
living expenses. |
Total Income |
Necessary Living Expenses |
Source |
Gross |
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Claimed |
Allowed |
31. Wages/salaries (T/P) |
$ |
42. National Standard Expense |
$ |
$ |
32. Wages/salaries (spouse) |
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43. Housing and Utilities |
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33. Interest -- Dividends |
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44. Transportation |
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34. Net business income (from Form
433-B) |
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45. Health Care |
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35. Rental Income |
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46. Taxes |
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36. Pension (T/P) |
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47. Court ordered payments |
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37. Pension (spouse) |
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48. Child/dependent care |
|
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38. Child support |
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49. Life insurance |
|
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39. Alimony |
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50. Secured or legally perfected debt
(specify) |
|
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40. Other |
|
51. Other expenses (specify) |
|
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|
|
|
|
|
|
|
|
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|
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41. Total Income |
$ |
52. Total Expenses |
$ |
$ |
(Line 41 minus
line 52) NET DIFFERENCE |
$ |
53. Net
difference times (a, b, or c) = Amount
that could be paid from future income:
_______ x_______ =_______
a) If taxpayer is making a cash offer
(offering to pay in 90 days or less)
multiply the amount in line 53 times 48 or
the number of months remaining on the
statute.
b) If the taxpayer is making a short term
deferred payment offer, (offering to pay
within 2 years) multiply the amount in
line 53 times 60 months or times the
number of months remaining on the
collection statute, whichever is shorter.
c) If the taxpayer is making a deferred
payment offer (offering to pay over the
life of the statute), use the Deferred
Payment Offer Chart to determine the
number of months. |
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Total offer must equal sum
of equity in assets and amount that could
be paid from future income unless special
circumstance considerations have been
approved. |
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Exhibit
[5.8] 4-3 (02-04-2000)
Offer in Compromise Recommendation Report
Exhibit
[5.8] 4-3 (Cont.) (02-04-2000)
Offer in Compromise Recommendation Report
|
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Internal Revenue Manual
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Hndbk. 5.8 Chap. 4 Evaluation
of Offers
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(02-04-2000)
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