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Attorney Criticizes Proposed OIC Fees

NOV. 12, 2002

Attorney Criticizes Proposed OIC Fees

DATED NOV. 12, 2002
DOCUMENT ATTRIBUTES
  • Authors
    Falcone, Joseph
  • Cross-Reference
    For a summary of REG-103777-02, see Tax Notes, Nov. 11, 2002, p. 757;

    for the full text, see Doc 2002-24876 (4 original pages), 2002 TNT

    218-85 Database 'Tax Notes Today 2002', View '(Number', or H&D, Nov. 6, 2002, p. 1229.
  • Code Sections
  • Subject Area/Tax Topics
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2002-26065 (1 original page)
  • Tax Analysts Electronic Citation
    2002 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.

Joseph Falcone

 

Southfield, MI
DOCUMENT ATTRIBUTES
  • Authors
    Falcone, Joseph
  • Cross-Reference
    For a summary of REG-103777-02, see Tax Notes, Nov. 11, 2002, p. 757;

    for the full text, see Doc 2002-24876 (4 original pages), 2002 TNT

    218-85 Database 'Tax Notes Today 2002', View '(Number', or H&D, Nov. 6, 2002, p. 1229.
  • Code Sections
  • Subject Area/Tax Topics
  • Jurisdictions
  • Language
    English
  • Tax Analysts Document Number
    Doc 2002-26065 (1 original page)
  • Tax Analysts Electronic Citation
    2002 TNT 235-16
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