Accountant Strongly Criticizes Proposed User Fees for OICs

From: postoffice@www.qai.irs.gov

[2] Opposed to for the following reasons:

1) This is a service to be provided by the IRS, funded by tax dollars. The establishment of fees is a poor precedent. What's next - - a fee to file a tax return. Again -- a poor precedent.

2) Most offers in compromise are made by people with insufficient funds. The proverty guidelines are inadequate to cover the majority of people with insufficient financial capacity.

3) The establishment of a fee erects another barrier. Is the true purpose of charging a fee to discourage offers in compromise, because most of the filers do not have adequate funds? The charging of such a fee goes against the grain of fair play. The IRS should not be establishing obstacles to comply with duely established filing procedures and alternatives provided to the taxpayer.

4) The proposed regulations of determining who doesn't pay and when to refund the fee are too subjective. Compliance with the fee collection rule alone will be expensive, thus reducing the net revenue the IRS proposes to collect by assessing fees.

5) If the US Government wants to continue to assess user fees, then I strongly suggest the US Government seriously consider privatizing the majority of governmental functions. Dramatic cost savings will result via privatization. Naturally, we need to careful on what to privatize -- for example, it is immoral to make money on imprisoning people; however, jail house money makers (privatization) was one of the first to occur. Expanding this -- offers in compromise do not belong in the "privatization", "fee generating" arena either.