Page 29 - OIC Guide

OTHER IM PORTANT FACTS

- The IRS can't process your offer if the IRS referred your case,

or cases, involving all of the liabilities identified in the offer

to the Department of Justice.

- In addition, the IRS cannot compromise any tax liability

arising from a restitution amount ordered by a court or a

tax debt reduced to judgment.

- Furthermore, the IRS will not compromise any IRC § 965 tax

liability for which an election was made under IRC § 965(i).

You cannot appeal this decision.

- Not e: Any offer cont aining a liabilit y for which payment

is being deferred under IRC § 965(h)(1) can only be

processed for invest igat ion if an accelerat ion of

payment under sect ion 965(h)(3) and t he regulat ions

t hereunder has occurred and no port ion of t he liabilit y

t o be compromised result ed from ent ering int o a

t ransfer agreement under sect ion 965(h)(3).

LENINTHOMAS@CPA PLLC