| For any Attorneys, CPAs, or Enrolled Agents looking | | | | current law creates an opportunity for taxpayers who |
| to pursue resolutions and offers in comprise for their | | | | would like to pursue an offer in compromise but are |
| clients or potential clients in 2011, large growth in the | | | | not willing or are unable to pay the initial sums due. |
| resolution industry is a possibility. | | | | As written in the Administrations fiscal year 2011 |
| The law for offers in compromise, as of right now, | | | | revenue proposals. The new proposal would eliminate |
| requires taxpayers to make certain nonrefundable | | | | the requirements that an initial offer in compromise |
| payments with any initial offer in compromise | | | | submission include a nonrefundable payment of any |
| submission. This new provision was introduced in 2006 | | | | portion of the taxpayer's offer. The proposal would be |
| and required taxpayers who request certain lump-sum | | | | effective for offers in compromise submitted after the |
| offers in compromise to pay 20% of the offer amount | | | | date of enactment. |
| with the initial request. In the case of an offer in | | | | With this change, Attorneys, CPAs, and Enrolled |
| compromise involving periodic payments, the initial offer | | | | Agents will potentially see a large increase in |
| must be accompanied by a nonrefundable payment | | | | taxpayers willing and able to begin the resolution |
| equal to the first installment payment, and the | | | | process with the IRS. Continual changes such as this |
| nonrefundable installments must be continued while the | | | | are why every Enrolled Agent should go through |
| offer is reviewed by the IRS. | | | | routine EA training or take an Enrolled Agent course |
| The offer-in-compromise program is designed to settle | | | | that reviews IRS collection procedures at least once a |
| cases in which taxpayers have demonstrated an | | | | year. |
| inability to pay the full amount of a tax liability. The | | | | |