Course Category: Appellate Review

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OIC 121: Rejecting a Pending Offer

“Rejecting” a Pending Offer. The IRS can “reject” a processable Offer in Compromise application for many reasons.  The IRS defines “reject” as a non-acceptance recommendation of any OIC offer that includes appellate rights.  IRM § (12-20-2018).  The rejection of an application closes the Offer in Compromise application review process. …

OIC 126: Appellate Rights

Appellate Rights Relating to OICs. This course discusses appellate rights in the Offer in Compromise context.  Appellate rights are better understood when segregated into three issues: (1) appellate rights relating to a pre-rejection “independent administrative review”; (2) appellate rights following a collection due process determination (i.e.  offer made as part of…

IA 102: Levy Protection with Installment Agreements

Levy Protection Afforded by Installment Agreements. Installment agreements are employed to shield taxpayers from the IRS’ dreaded levy apparatus while paying back-taxes through a systematic repayment plan.  The IRS’ most lethal collection weapon is the feared LEVY.  The IRS uses the levy as a sword against taxpayers by seizing taxpayers’ money…

IA 110: IRS Acceptance & Rejection Determinations

IRS Acceptance & Rejection Determinations. Acceptance or rejection of a proposed “routine” installment agreement is based on analysis of (a) compliance with filing and payment requirements, (b) collection information statements, and (c) taxpayer provided documentation.  As explained in other lessons, special criteria exist for those taxpayers who qualify for Guaranteed,…

IA 111: Terminating & Modifying Existing Agreements

Terminating & Modifying Existing Installment Agreements. Generally, an installment agreement approved by the IRS remains in effect for the stated term of the agreement.  26 U.S.C. § 6159(b)(1).  However, a taxpayer may request that the IRS alter, modify or terminate the terms of the installment agreement because of a change…

IA 112: Appellate Review

Appellate Review. The Tax Code requires the IRS to conduct an “independent administrative review” before the rejection of an installment agreement is communicated to the taxpayer.  26 U.S.C. § 7122(e).  Although the intention to recommend rejection should be relayed to the taxpayer, actual rejection of a proposed agreement must not be…

ISR 107: Appellate Review

Appellate Review. This course discusses a Requesting Spouse’s appellate rights both (a) when the IRS fails to issue a “preliminary” determination within six (6) months of the election for Innocent Spouse Relief and/or Separation of Liability Relief, or request for Equitable Relief, and (b) after an IRS determination denying the…