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Title 26 — Internal Revenue Code

Chapter 74 — Closing Agreements and Compromises

§ 7122. Compromises

Statutory text

(a)

Authorization

The Secretary may compromise any civil or criminal case arising under the internal revenue laws prior to reference to the Department of Justice for prosecution or defense; and the Attorney General or his delegate may compromise any such case after reference to the Department of Justice for prosecution or defense.

(b)

Record

Whenever a compromise is made by the Secretary in any case, there shall be placed on file in the office of the Secretary the opinion of the General Counsel for the Department of the Treasury or his delegate, with his reasons therefor, with a statement of—

(1)

The amount of tax assessed,

(2)

The amount of interest, additional amount, addition to the tax, or assessable penalty, imposed by law on the person against whom the tax is assessed, and

(3)

The amount actually paid in accordance with the terms of the compromise.

Notwithstanding the foregoing provisions of this subsection, no such opinion shall be required with respect to the compromise of any civil case in which the unpaid amount of tax assessed (including any interest, additional amount, addition to the tax, or assessable penalty) is less than $50,000. However, such compromise shall be subject to continuing quality review by the Secretary.

(c)

Rules for submission of offers-in-compromise

(1)

Partial payment required with submission

(A)

Lump-sum offers

(i)

In general

The submission of any lump-sum offer-in-compromise shall be accompanied by the payment of 20 percent of the amount of such offer.

(ii)

Lump-sum offer-in-compromise

For purposes of this section, the term “lump-sum offer-in-compromise” means any offer of payments made in 5 or fewer installments.

(B)

Periodic payment offers

(i)

In general

The submission of any periodic payment offer-in-compromise shall be accompanied by the payment of the amount of the first proposed installment.

(ii)

Failure to make installment during pendency of offer

Any failure to make an installment (other than the first installment) due under such offer-in-compromise during the period such offer is being evaluated by the Secretary may be treated by the Secretary as a withdrawal of such offer-in-compromise.

(2)

Rules of application

(A)

Use of payment

The application of any payment made under this subsection to the assessed tax or other amounts imposed under this title with respect to such tax may be specified by the taxpayer.

(B)

Application of user fee

In the case of any assessed tax or other amounts imposed under this title with respect to such tax which is the subject of an offer-in-compromise to which this subsection applies, such tax or other amounts shall be reduced by any user fee imposed under this title with respect to such offer-in-compromise.

(C)

Waiver authority

The Secretary may issue regulations waiving any payment required under paragraph (1) in a manner consistent with the practices established in accordance with the requirements under subsection (d)(3).

(3)

Exception for low-income taxpayers

Paragraph (1), and any user fee otherwise required in connection with the submission of an offer-in-compromise, shall not apply to any offer-in-compromise with respect to a taxpayer who is an individual with adjusted gross income, as determined for the most recent taxable year for which such information is available, which does not exceed 250 percent of the applicable poverty level (as determined by the Secretary).

(d)

Standards for evaluation of offers

(1)

In general

The Secretary shall prescribe guidelines for officers and employees of the Internal Revenue Service to determine whether an offer-in-compromise is adequate and should be accepted to resolve a dispute.

(2)

Allowances for basic living expenses

(A)

In general

In prescribing guidelines under paragraph (1), the Secretary shall develop and publish schedules of national and local allowances designed to provide that taxpayers entering into a compromise have an adequate means to provide for basic living expenses.

(B)

Use of schedules

The guidelines shall provide that officers and employees of the Internal Revenue Service shall determine, on the basis of the facts and circumstances of each taxpayer, whether the use of the schedules published under subparagraph (A) is appropriate and shall not use the schedules to the extent such use would result in the taxpayer not having adequate means to provide for basic living expenses.

(3)

Special rules relating to treatment of offers

The guidelines under paragraph (1) shall provide that—

(A)

an officer or employee of the Internal Revenue Service shall not reject an offer-in-compromise from a low-income taxpayer solely on the basis of the amount of the offer,

(B)

in the case of an offer-in-compromise which relates only to issues of liability of the taxpayer—

(i)

such offer shall not be rejected solely because the Secretary is unable to locate the taxpayer’s return or return information for verification of such liability; and

(ii)

the taxpayer shall not be required to provide a financial statement, and

(C)

any offer-in-compromise which does not meet the requirements of subparagraph (A)(i) or (B)(i), as the case may be, of subsection (c)(1) may be returned to the taxpayer as unprocessable.

(e)

Administrative review

The Secretary shall establish procedures—

(1)

for an independent administrative review of any rejection of a proposed offer-in-compromise or installment agreement made by a taxpayer under this section or section 6159 before such rejection is communicated to the taxpayer; and

(2)

which allow a taxpayer to appeal any rejection of such offer or agreement to the Internal Revenue Service Independent Office of Appeals.

(f)

Deemed acceptance of offer not rejected within certain period

Any offer-in-compromise submitted under this section shall be deemed to be accepted by the Secretary if such offer is not rejected by the Secretary before the date which is 24 months after the date of the submission of such offer. For purposes of the preceding sentence, any period during which any tax liability which is the subject of such offer-in-compromise is in dispute in any judicial proceeding shall not be taken into account in determining the expiration of the 24-month period.

(g)

Frivolous submissions, etc.

Notwithstanding any other provision of this section, if the Secretary determines that any portion of an application for an offer-in-compromise or installment agreement submitted under this section or section 6159 meets the requirement of clause (i) or (ii) of section 6702(b)(2)(A), then the Secretary may treat such portion as if it were never submitted and such portion shall not be subject to any further administrative or judicial review.

Legislative history

Reconstructed from this section’s Code source credit and amendment notes, resolved against the local Statutes at Large. Editorial notes are evidence, not the law that made the change.

  1. Aug. 16, 1954, ch. 736, 68A Stat. 849 · 68A Stat. 849

    Enacted · 26 U.S.C. § 7122

    Aug. 16, 1954, ch. 736, 68A Stat. 849

    Source evidence

    Code source credit
    Aug. 16, 1954, ch. 736, 68A Stat. 849

  2. Pub. L. 94–455 title XIX § 1906(b)(13)(A) · 90 Stat. 1520

    Struck · 26 U.S.C. § 7122(a); 26 U.S.C. § 7122(b)

    Pub. L. 94–455 struck out “or his delegate” after “Secretary”

    Source evidence

    Code amendment note
    Subsecs. (a), (b). Pub. L. 94–455 struck out “or his delegate” after “Secretary”.

    Enacted provision · exact public law section
    (A) The Internal Revenue Code of 1954, as amended by this Act, is amended by striking out “Secretary or his delegate” each place it appears and inserting in lieu thereof “Secretary”.

  3. Taxpayer Bill of Rights 2

    Pub. L. 104–168 title V § 503(a) · 110 Stat. 1452

    Substituted · 26 U.S.C. § 7122(b)

    Pub. L. 104–168 substituted “$50,000. However, such compromise shall be subject to continuing quality review by the Secretary.” for “$500.”

    Source evidence

    Code amendment note
    Subsec. (b). Pub. L. 104–168 substituted “$50,000. However, such compromise shall be subject to continuing quality review by the Secretary.” for “$500.”

    Enacted provision · exact public law section
    (a) Review Requirements.— Subsection (b) of section 7122 (relating to records) is amended by striking “$500.” and inserting “$50,000. However, such compromise shall be subject to continuing quality review by the Secretary.”.

  4. Taxpayer Bill of Rights 3

    Pub. L. 105–206 § 3462(a) · 112 Stat. 685

    Added · 26 U.S.C. § 7122(c)

    Pub. L. 105–206, § 3462(a), added subsec. (c)

    Source evidence

    Code amendment note
    Subsec. (c). Pub. L. 105–206, § 3462(a), added subsec. (c).

    Enacted provision · exact public law section
    (a) Standards for Evaluation of Offers in Compromise.— Section 7122 (relating to offers-in-compromise) is amended by adding at the end the following new subsection: “(c) Guidelines. Standards for Evaluation of Offers.— “(1) In general.— The Secretary shall prescribe guidelines for officers and employees of the Internal Revenue Service to determine whether an offer-in-compromise is adequate and should be accepted to resolve a dispute. “(2) Allowances for basic living expenses.— “(A) In general.— In prescribing guidelines under Publication. paragraph (1), the Secretary shall develop and publish schedules of national and local allowances designed to provide that taxpayers entering into a compromise have an adequate means to provide for basic living expenses. “(B) Use of schedules.— The guidelines shall provide that officers and employees of the Internal Revenue Service shall determine, on the basis of the facts and circumstances of each taxpayer, whether the use of the schedules published under subparagraph (A) is appropriate and shall not use the schedules to the extent such use would result in the taxpayer not having adequate means to provide for basic living expenses. “(3) Special rules relating to treatment of offers.— The guidelines under paragraph (1) shall provide that— “(A) an officer or employee of the Internal Revenue Service shall not reject an offer-in-compromise from a low- income taxpayer solely on the basis of the amount of the offer; and “(B) in the case of an offer-in-compromise which relates only to issues of liability of the taxpayer— “(i) such offer shall not be rejected solely because the Secretary is unable to locate the taxpayer’s return or return information for verification of such liability; and “(ii) the taxpayer shall not be required to provide a financial statement.”.

  5. Taxpayer Bill of Rights 3

    Pub. L. 105–206 § 3462(c)(1) · 112 Stat. 685

    Added · 26 U.S.C. § 7122(d)

    Pub. L. 105–206, § 3462(c)(1), added subsec. (d)

    Source evidence

    Code amendment note
    Subsec. (d). Pub. L. 105–206, § 3462(c)(1), added subsec. (d).

    Enacted provision · exact public law section
    (1) In general.— Section 7122 (relating to compromises), as amended by subsection (a), is amended by adding at the end the following new subsection: “(d) Procedures. Administrative Review.— The Secretary shall establish procedures “(1) for an independent administrative review of any rejection of a proposed offer-in-compromise or installment agreement made by a taxpayer under this section or section 6159 before such rejection is communicated to the taxpayer; and “(2) which allow a taxpayer to appeal any rejection of such offer or agreement to the Internal Revenue Service Office of Appeals.”.

  6. Pub. L. 109–222 § 509(a) · 120 Stat. 345

    Redesignated · 26 U.S.C. § 7122(c)

    Pub. L. 109–222, § 509(a), added subsec. (c). Former subsec. (c) redesignated (d)

    Source evidence

    Code amendment note
    Subsec. (c). Pub. L. 109–222, § 509(a), added subsec. (c). Former subsec. (c) redesignated (d).

    Enacted provision · exact public law section
    (a) In General.— Section 7122 (relating to compromises) is amended by redesignating subsections (c) and (d) as subsections (d) and (e), respectively, and by inserting after subsection (b) the following new subsection: “(c) Rules for Submission of Offers-in-Compromise.— “(1) Partial payment required with submission.— “(A) Lump-sum offers.— “(i) In general.— The submission of any lump-sum offer-in-compromise shall be accompanied by the payment of 20 percent of the amount of such offer. “(ii) Lump-sum offer-in-compromise.— For purposes of this section, the term ‘lump-sum offer-in-compromise’ means any offer of payments made in 5 or fewer installments. “(B) Periodic payment offers.— “(i) In general.— The submission of any periodic payment offer-in-compromise shall be accompanied by the payment of the amount of the first proposed installment. “(ii) Failure to make installment during pendency of offer.— Any failure to make an installment (other than the first installment) due under such offer-in-compromise during the period such offer is being evaluated by the Secretary may be treated by the Secretary as a withdrawal of such offer-in-compromise. “(2) Rules of application.— “(A) Use of payment.— The application of any payment made under this subsection to the assessed tax or other amounts imposed under this title with respect to such tax may be specified by the taxpayer. “(B) Application of user fee.— In the case of any assessed tax or other amounts imposed under this title with respect to such tax which is the subject of an offer-in-compromise to which this subsection applies, such tax or other amounts shall be reduced by any user fee imposed under this title with respect to such offer-in-compromise. “(C) Waiver authority.— The Secretary may issue regulations waiving any payment required under paragraph (1) in a manner consistent with the practices established in accordance with the requirements under subsection (d)(3).” .

  7. Pub. L. 109–222 § 509(a) · 120 Stat. 345

    Redesignated · 26 U.S.C. § 7122(d)

    Pub. L. 109–222, § 509(a), redesignated subsec. (c) as (d). Former subsec. (d) redesignated (e)

    Source evidence

    Code amendment note
    Subsec. (d). Pub. L. 109–222, § 509(a), redesignated subsec. (c) as (d). Former subsec. (d) redesignated (e).

    Enacted provision · exact public law section
    (a) In General.— Section 7122 (relating to compromises) is amended by redesignating subsections (c) and (d) as subsections (d) and (e), respectively, and by inserting after subsection (b) the following new subsection: “(c) Rules for Submission of Offers-in-Compromise.— “(1) Partial payment required with submission.— “(A) Lump-sum offers.— “(i) In general.— The submission of any lump-sum offer-in-compromise shall be accompanied by the payment of 20 percent of the amount of such offer. “(ii) Lump-sum offer-in-compromise.— For purposes of this section, the term ‘lump-sum offer-in-compromise’ means any offer of payments made in 5 or fewer installments. “(B) Periodic payment offers.— “(i) In general.— The submission of any periodic payment offer-in-compromise shall be accompanied by the payment of the amount of the first proposed installment. “(ii) Failure to make installment during pendency of offer.— Any failure to make an installment (other than the first installment) due under such offer-in-compromise during the period such offer is being evaluated by the Secretary may be treated by the Secretary as a withdrawal of such offer-in-compromise. “(2) Rules of application.— “(A) Use of payment.— The application of any payment made under this subsection to the assessed tax or other amounts imposed under this title with respect to such tax may be specified by the taxpayer. “(B) Application of user fee.— In the case of any assessed tax or other amounts imposed under this title with respect to such tax which is the subject of an offer-in-compromise to which this subsection applies, such tax or other amounts shall be reduced by any user fee imposed under this title with respect to such offer-in-compromise. “(C) Waiver authority.— The Secretary may issue regulations waiving any payment required under paragraph (1) in a manner consistent with the practices established in accordance with the requirements under subsection (d)(3).” .

  8. Pub. L. 109–222 § 509(b)(1) · 120 Stat. 345

    Added · 26 U.S.C. § 7122(d)(3)(C)

    Pub. L. 109–222, § 509(b)(1), added subpar. (C)

    Source evidence

    Code amendment note
    Subsec. (d)(3)(C). Pub. L. 109–222, § 509(b)(1), added subpar. (C).

    Enacted provision · exact public law section
    (1) Unprocessable offer if payment requirements are not met.— Paragraph (3) of 26 USC 7122. section 7122(d) (relating to standards for evaluation of offers), as redesignated by subsection (a), is amended by striking “; and” at the end of subparagraph (A) and inserting a comma, by striking the period at the end of subparagraph (B) and inserting “, and”, and by adding at the end the following new subparagraph: “(C) any offer-in-compromise which does not meet the requirements of subparagraph (A)(i) or (B)(i), as the case may be, of subsection (c)(1) may be returned to the taxpayer as unprocessable.” .

  9. Pub. L. 109–222 § 509(a) · 120 Stat. 345

    Redesignated · 26 U.S.C. § 7122(e)

    Pub. L. 109–222, § 509(a), redesignated subsec. (d) as (e)

    Source evidence

    Code amendment note
    Subsec. (e). Pub. L. 109–222, § 509(a), redesignated subsec. (d) as (e).

    Enacted provision · exact public law section
    (a) In General.— Section 7122 (relating to compromises) is amended by redesignating subsections (c) and (d) as subsections (d) and (e), respectively, and by inserting after subsection (b) the following new subsection: “(c) Rules for Submission of Offers-in-Compromise.— “(1) Partial payment required with submission.— “(A) Lump-sum offers.— “(i) In general.— The submission of any lump-sum offer-in-compromise shall be accompanied by the payment of 20 percent of the amount of such offer. “(ii) Lump-sum offer-in-compromise.— For purposes of this section, the term ‘lump-sum offer-in-compromise’ means any offer of payments made in 5 or fewer installments. “(B) Periodic payment offers.— “(i) In general.— The submission of any periodic payment offer-in-compromise shall be accompanied by the payment of the amount of the first proposed installment. “(ii) Failure to make installment during pendency of offer.— Any failure to make an installment (other than the first installment) due under such offer-in-compromise during the period such offer is being evaluated by the Secretary may be treated by the Secretary as a withdrawal of such offer-in-compromise. “(2) Rules of application.— “(A) Use of payment.— The application of any payment made under this subsection to the assessed tax or other amounts imposed under this title with respect to such tax may be specified by the taxpayer. “(B) Application of user fee.— In the case of any assessed tax or other amounts imposed under this title with respect to such tax which is the subject of an offer-in-compromise to which this subsection applies, such tax or other amounts shall be reduced by any user fee imposed under this title with respect to such offer-in-compromise. “(C) Waiver authority.— The Secretary may issue regulations waiving any payment required under paragraph (1) in a manner consistent with the practices established in accordance with the requirements under subsection (d)(3).” .

  10. Pub. L. 109–222 § 509(b)(2) · 120 Stat. 345

    Added · 26 U.S.C. § 7122(f)

    Pub. L. 109–222, § 509(b)(2), added subsec. (f) relating to deemed acceptance of offer not rejected within certain period

    Target inherited from the preceding amendment note.

    Source evidence

    Code amendment note
    Pub. L. 109–222, § 509(b)(2), added subsec. (f) relating to deemed acceptance of offer not rejected within certain period.

    Enacted provision · exact public law section
    (2) Deemed acceptance of offer not rejected within certain period.— Section 7122, as amended by subsection (a), is amended by adding at the end the following new subsection: “(f) Deemed Acceptance of Offer Not Rejected Within Certain Period.— Any offer-in-compromise submitted under this section shall be deemed to be accepted by the Secretary if such offer is not rejected by the Secretary before the date which is 24 months after the date of the submission of such offer. For purposes of the preceding sentence, any period during which any tax liability which is the subject of such offer-in-compromise is in dispute in any judicial proceeding shall not be taken into account in determining the expiration of the 24-month period.” .

  11. Tax Relief and Health Care Act of 2006

    Pub. L. 109–432 div. A title IV § 407(d) · 120 Stat. 2922

    Added · 26 U.S.C. § 7122(f)

    Pub. L. 109–432 added subsec. (f) relating to frivolous submissions

    Source evidence

    Code amendment note
    Subsec. (f). Pub. L. 109–432 added subsec. (f) relating to frivolous submissions.

    Enacted provision · exact public law section
    (d) Treatment of Frivolous Applications for Offers-in-Compromise and Installment Agreements.— Section 7122 is amended by adding at the end the following new subsection: “(f) Frivolous Submissions, etc.— Notwithstanding any other provision of this section, if the Secretary determines that any portion of an application for an offer-in-compromise or installment agreement submitted under this section or section 6159 meets the requirement of clause (i) or (ii) of section 6702(b)(2)(A), then the Secretary may treat such portion as if it were never submitted and such portion shall not be subject to any further administrative or judicial review.” .

  12. Tax Technical Corrections Act of 2014

    Pub. L. 113–295 div. A title II § 220(y) · 128 Stat. 4010

    Redesignated · 26 U.S.C. § 7122(f); 26 U.S.C. § 7122(g)

    Pub. L. 113–295 redesignated subsec. (f) relating to frivolous submissions as (g)

    Source evidence

    Code amendment note
    Subsecs. (f), (g). Pub. L. 113–295 redesignated subsec. (f) relating to frivolous submissions as (g).

    Enacted provision · exact public law section
    (y) Section 7122 is amended by redesignating the second subsection (f) (relating to frivolous submissions, etc.) as subsection (g).

  13. Taxpayer First Act

    Pub. L. 116–25 § 1102(a) · 133 Stat. 981

    Added · 26 U.S.C. § 7122(c)(3)

    Pub. L. 116–25, § 1102(a), added par. (3)

    Source evidence

    Code amendment note
    Subsec. (c)(3). Pub. L. 116–25, § 1102(a), added par. (3).

    Enacted provision · exact public law section
    (a) In General.— Section 7122(c) is amended by adding at the end the following new paragraph: “(3) Exception for low-income taxpayers.— Paragraph (1), and any user fee otherwise required in connection with the submission of an offer-in-compromise, shall not apply to any offer-in-compromise with respect to a taxpayer who is an individual with adjusted gross income, as determined for the most recent taxable year for which such information is available, which does not exceed 250 percent of the applicable poverty level (as determined by the Secretary).” .

    Effective date note
    Pub. L. 116–25, title I, § 1102(b), July 1, 2019, 133 Stat. 986, provided that: “The amendment made by this section [amending this section] shall apply to offers-in-compromise submitted after the date of the enactment of this Act [July 1, 2019].”

  14. Taxpayer First Act

    Pub. L. 116–25 § 1001(b)(1)(F) · 133 Stat. 981

    Substituted · 26 U.S.C. § 7122(e)(2)

    Pub. L. 116–25, § 1001(b)(1)(F), substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals”

    Source evidence

    Code amendment note
    Subsec. (e)(2). Pub. L. 116–25, § 1001(b)(1)(F), substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals”.

    Enacted provision · exact public law section
    (F) Section 7122(e)(2).

    Effective date note
    Pub. L. 116–25, title I, § 1102(b), July 1, 2019, 133 Stat. 986, provided that: “The amendment made by this section [amending this section] shall apply to offers-in-compromise submitted after the date of the enactment of this Act [July 1, 2019].”

13 of 14 references resolved to an enrolled provision · 1 partial

Editorial Notes

Amendments1976–2019 · 6 rounds

2019

Subsec. (c)(3). Pub. L. 116–25, § 1102(a), added par. (3).

Subsec. (e)(2). Pub. L. 116–25, § 1001(b)(1)(F), substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals”.

2014

Subsecs. (f), (g). Pub. L. 113–295 redesignated subsec. (f) relating to frivolous submissions as (g).

2006

Subsec. (c). Pub. L. 109–222, § 509(a), added subsec. (c). Former subsec. (c) redesignated (d).

Subsec. (d). Pub. L. 109–222, § 509(a), redesignated subsec. (c) as (d). Former subsec. (d) redesignated (e).

Subsec. (d)(3)(C). Pub. L. 109–222, § 509(b)(1), added subpar. (C).

Subsec. (e). Pub. L. 109–222, § 509(a), redesignated subsec. (d) as (e).

Subsec. (f). Pub. L. 109–432 added subsec. (f) relating to frivolous submissions.

Pub. L. 109–222, § 509(b)(2), added subsec. (f) relating to deemed acceptance of offer not rejected within certain period.

1998

Subsec. (c). Pub. L. 105–206, § 3462(a), added subsec. (c).

Subsec. (d). Pub. L. 105–206, § 3462(c)(1), added subsec. (d).

1996

Subsec. (b). Pub. L. 104–168 substituted “$50,000. However, such compromise shall be subject to continuing quality review by the Secretary.” for “$500.”

1976

Subsecs. (a), (b). Pub. L. 94–455 struck out “or his delegate” after “Secretary”.

Statutory Notes and Related Subsidiaries

Effective Date of 2019 Amendment

Pub. L. 116–25, title I, § 1102(b), , 133 Stat. 986, provided that: “The amendment made by this section [amending this section] shall apply to offers-in-compromise submitted after the date of the enactment of this Act [].”

Effective Date of 2006 Amendment

Amendment by Pub. L. 109–432 applicable to submissions made and issues raised after the date on which the Secretary first prescribes a list under section 6702(c) of this title, see section 407(f) of Pub. L. 109–432, set out as a note under section 6320 of this title.

Amendment by Pub. L. 109–222 applicable to offers-in-compromise submitted on and after the date which is 60 days after , see section 509(d) of Pub. L. 109–222, set out as a note under section 6159 of this title.

Effective Date of 1998 Amendment

Amendment by Pub. L. 105–206 applicable to proposed offers-in-compromise and installment agreements submitted after , see section 3462(e)(1) of Pub. L. 105–206, set out as a note under section 6331 of this title.

Effective Date of 1996 Amendment

Pub. L. 104–168, title V, § 503(b), , 110 Stat. 1461, provided that: “The amendment made by this section [amending this section] shall take effect on the date of the enactment of this Act [].”

Preparation of Statement Relating to Offers-in-Compromise

Pub. L. 105–206, title III, § 3462(d), , 112 Stat. 766, provided that:

“The Secretary of the Treasury shall prepare a statement which sets forth in simple, nontechnical terms the rights of a taxpayer and the obligations of the Internal Revenue Service relating to offers-in-compromise. Such statement shall—

“(1)

advise taxpayers who have entered into a compromise of the advantages of promptly notifying the Internal Revenue Service of any change of address or marital status;

“(2)

provide notice to taxpayers that in the case of a compromise terminated due to the actions of one spouse or former spouse, the Internal Revenue Service will, upon application, reinstate such compromise with the spouse or former spouse who remains in compliance with such compromise; and

“(3)

provide notice to the taxpayer that the taxpayer may appeal the rejection of an offer-in-compromise to the Internal Revenue Service Office of Appeals [now Internal Revenue Service Independent Office of Appeals].”

Credits

1954–2019 · 8 acts
  1. 1954Aug. 16, 1954, ch. 736, 68A Stat. 849
  2. 1976Pub. L. 94–455, title XIX, § 1906(b)(13)(A), , 90 Stat. 1834
  3. 1996Pub. L. 104–168, title V, § 503(a), , 110 Stat. 1461
  4. 1998Pub. L. 105–206, title III, § 3462(a), (c)(1), , 112 Stat. 764, 766
  5. 2006Pub. L. 109–222, title V, § 509(a), (b), , 120 Stat. 362, 363
  6. 2006Pub. L. 109–432, div. A, title IV, § 407(d), , 120 Stat. 2962
  7. 2014Pub. L. 113–295, div. A, title II, § 220(y), , 128 Stat. 4036
  8. 2019Pub. L. 116–25, title I, §§ 1001(b)(1)(F), 1102(a), , 133 Stat. 985, 986.
Show as published

(Aug. 16, 1954, ch. 736, 68A Stat. 849; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), , 90 Stat. 1834; Pub. L. 104–168, title V, § 503(a), , 110 Stat. 1461; Pub. L. 105–206, title III, § 3462(a), (c)(1), , 112 Stat. 764, 766; Pub. L. 109–222, title V, § 509(a), (b), , 120 Stat. 362, 363; Pub. L. 109–432, div. A, title IV, § 407(d), , 120 Stat. 2962; Pub. L. 113–295, div. A, title II, § 220(y), , 128 Stat. 4036; Pub. L. 116–25, title I, §§ 1001(b)(1)(F), 1102(a), , 133 Stat. 985, 986.)

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