Treasury would consider as an acceptable revised offer in compromise by the taxpayer. In this situation, Treasury may send a letter to the taxpayer and any third party designated representative that states the following: The amount of a revised offer in compromise that Treasury would consider acceptable; The reasons why analysis supports the revised offer in compromise as Treasury’s acceptable; and That the taxpayer must notify Treasury in writing within 20 calendar days of the date of that the taxpayer submits determined amount Treasury’s letter Treasury’s as the revised offer in compromise, and that failure of the taxpayer to taxpayer’s do so will be deemed as a decision not to submit a revised offer and the taxpayer’s submitted offer in compromise is rejected. If Treasury rejects an offer in compromise, it will send a rejection letter to the taxpayer and any third party designated representative. The letter must state that the offer in compromise is rejected, state the reasons for the rejection and that the taxpayer may request an independent administrative review of decision by filing a written Treasury’s request on Form 5186 Request for Independent Administrative Review of Rejected Offer within 30 days after the date of rejection letter. Treasury may initiate in Compromise collection activities after issuing the rejection letter. Once a taxpayer files a written request for independent administrative review, Treasury must suspend collection and may not levy against any property or assets to collect the tax debt while the independent administrative review is pending, unless Treasury determines that the offer in taxpayer’s compromise was solely intended to delay collection of the tax or Treasury determines the need to issue a jeopardy assessment. 2.4 Examination of Offers Based on Grant by the IRS of Federal Compromise under Section 7122 of the Internal Revenue Code Considering an Offer in Compromise Based on Grant of a Federal Offer in Compromise A taxpayer may submit an offer in compromise of a tax debt if the taxpayer was granted a federal compromise of tax under section 7122 of the Internal Revenue Code for the same tax periods. Treasury may accept a offer in compromise on this basis if the taxpayer’s taxpayer has otherwise satisfied all of the conditions necessary to submit an offer in compromise under section 23a of the Revenue Act, MCL 205.23a, which are the following: a. The taxpayer is not in bankruptcy; b. The taxpayer paid the required payment of $100.00 or 20% of the offer, whichever is greater; c. The tax liability included in the offer in compromise has been assessed by Treasury; ;
Treasury would consider as an acceptable revised offer in compromise by the taxpayer. In this situation, Treasury may send a letter to the taxpayer and any third party designated representative that states the following: The amount of a revised offer in compromise that Treasury would consider acceptable; The reasons why Treasury’s analysis supports the revised offer in compromise as acceptable; and That the taxpayer must notify Treasury in writing within 20 calendar days of the date of Treasury’s letter that the taxpayer submits Treasury’s determined amount as the taxpayer’s revised offer in compromise, and that failure of the taxpayer to do so will be deemed as a decision not to submit a revised offer and the taxpayer’s submitted offer in compromise is rejected. If Treasury rejects an offer in compromise, it will send a rejection letter to the taxpayer and any third party designated representative. The letter must state that the offer in compromise is rejected, state the reasons for the rejection and that the taxpayer may request an independent administrative review of Treasury’s decision by filing a written request on Form 5186 Request for Independent Administrative Review of Rejected Offer in Compromise within 30 days after the date of rejection letter. Treasury may initiate collection activities after issuing the rejection letter. Once a taxpayer files a written request for independent administrative review, Treasury must suspend collection and may not levy against any property or assets to collect the tax debt while the independent administrative review is pending, unless Treasury determines that the taxpayer’s offer in compromise was solely intended to delay collection of the tax or Treasury determines the need to issue a jeopardy assessment. 2.4 Examination of Offers Based on Grant by the IRS of Federal Compromise under Section 7122 of the Internal Revenue Code Considering an Offer in Compromise Based on Grant of a Federal Offer in Compromise A taxpayer may submit an offer in compromise of a tax debt if the taxpayer was granted a federal compromise of tax under section 7122 of the Internal Revenue Code for the same tax periods. Treasury may accept a taxpayer’s offer in compromise on this basis if the taxpayer has otherwise satisfied all of the conditions necessary to submit an offer in compromise under section 23a of the Revenue Act, MCL 205.23a, which are the following: a. The taxpayer is not in bankruptcy; b. The taxpayer paid the required payment of $100.00 or 20% of the offer, whichever is greater; c. The tax liability included in the offer in compromise has been assessed by Treasury; ;
Guidelines_for_Offer_in_Compromise_Program_Revised_11-17-16_549783_7.docx