Attorney Criticizes Proposed OIC Fees
Attorney Criticizes Proposed OIC Fees
- AuthorsFalcone, Joseph
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2002-26065 (1 original page)
- Tax Analysts Electronic Citation2002 TNT 235-16
From: postoffice@www.qai.irs.gov
Sent: Tuesday, November 12, 2002 7:42 AM
To: guy.r.traynor@irscounsel.treas.gov
Subject: Comment from Web Site
From: joefalcone
reg=User Fee for Processing Offers to Compromise
category=taxregs
[1] I am a practicing attorney who is a former District Counsel attorney. I started with IRS District Counsel in 1974 and have been in private practice since 1978. I am involved in a lot of offers in compromise.
[2] It is well known in the tax practice community that the IRS never really liked offers in compromise. Quite frankly, it appears that the IRS will work very hard to find a way to deny an offer in compromise.
[3] Imposing a fee for submitting an offer to pay the Government more money that it could collect through nonvoluntary collection activities seems to cement the belief that the IRS is not really serious about offers in compromise. Unfortunately, as it stands now, IRS Revenue Officers solcit offers in compromise as a way to "close" their cases.
[4] Anything that the IRS does to make it harder for people to give it money really does defeat the purpose of the offer in compromise system.
[5] All fees do is discourage the use of the procedure that the fee is imposed on. If that is what the IRS is trying to do, then the fee is a good thing.
[6] I would suggest that if the IRS is dying to charge a fee for this service that the fee be imposed after the offer is declined. Much like the fee the IRS now charges for filing a tax lien.
Southfield, MI
- AuthorsFalcone, Joseph
- Cross-Reference
- Code Sections
- Subject Area/Tax Topics
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2002-26065 (1 original page)
- Tax Analysts Electronic Citation2002 TNT 235-16