Tax News

CCH (cch.taxgroup.com) reports:

An IRS Appeals officer did not abuse her discretion when she issued a notice of determination without considering a married couple's offer-in-compromise (OIC) based only on doubt as to liability. Because the taxpayers received a notice of deficiency and had an opportunity to challenge the underlying tax liability, but failed to do so, they were barred from challenging the amount of the liability at the Collection Due Process (CDP) hearing. Therefore, the settlement officer properly refused to consider the taxpayers' OIC it was a prohibited challenge to the underlying tax liability.
E.S. Yesse, TC Memo 2008-157, Dec. 57,473(M)
Other References:
Code Sec. 6360
CCH Reference - 2008FED ¶38,184.12
Tax Research Consultant
CCH Reference - TRC IRS: 51,056