OCLC Number: 54393190 Excerpt: ...( including extensions ). The termination could occur even if the taxpayer remained current with payments under the installment agreement. Effective Date The proposal is effective for failures occurring on or after the date of enactment. 4. Office of Chief Counsel review of offers-in-compromise Present Law The IRS ...
OCLC Number: 54393190 Excerpt: ...( including extensions ). The termination could occur even if the taxpayer remained current with payments under the installment agreement. Effective Date The proposal is effective for failures occurring on or after the date of enactment. 4. Office of Chief Counsel review of offers-in-compromise Present Law The IRS has the authority to settle a tax debt pursuant to an offer-in-compromise. IRS regulations provide that such offers can be accepted if the taxpayer is unable to pay the full amount of the tax liability and it is doubtful that the tax, interest, and penalties can be collected or there is doubt as to the validity of the actual tax liability. Amounts of $ 50,000 or more can only be accepted if the reasons for the acceptance are documented in detail and supported by a written opinion from the IRS Chief Counsel ( sec. 7122 ). Description of Proposal The proposal repeals the requirement that an offer-in-compromise of $ 50,000 or more must be supported by a written opinion from the Office of Chief Counsel. Written opinions must only be provided if the Secretary determines that an opinion is required with respect to a compromise. Effective Date The proposal applies to offers-in-compromise submitted or pending on or after the date of enactment. 5. Permit the IRS to require increased electronic filing of returns prepared by paid return preparers Present Law The Code authorizes the IRS to issue regulations specifying which returns must be filed 6 electronically. There are several limitations on this authority. First, it can only apply to persons 7 required to file at least 250 returns during the year. Second, the IRS is prohibited from requiring that income tax returns of individuals, estates, and trusts be submitted in any format other than paper ( although these returns may by choice be filed electronically ). 6 Sec. 6011 ( e ). 7 Partnerships with more than 100 partners are required to file electronically. 4
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