(Used with permission,Volume 1, Issue 3:3 6 March, 2022 cdcbaa) Jon: Hi Aki. I can’t believe after knowing you for 30 years now that I don’t know where you were born. Aki: Ha! I was born in Tokyo, Japan although we moved to California when I was about one. We’ve been here ever since. Jon: Why the move? Aki: Well,...
Holding: IRS Did Not Abuse Its Discretion in Denying Debtor’s Offer-In-Compromise While Bankruptcy Case Was Pending
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By Morgan D. King, Esq. Dublin, CA
Salazar v. Commissioner of Internal Revenue, T.C. Memo. 2008-38 (U.S.T.C., 2008)
As respondent's counsel now explains, an offer-in-compromise must include all of the outstanding liabilities of the taxpayer. Further, section 6325(a) provides that the Commissioner "shall issue a certificate of release of any lien imposed with respect to any internal revenue tax" not later than 30 days after the liability for the amount has been fully satisfied.
Thus respondent argues, if respondent were to accept an offer-in-compromise and . . .
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