IRS Restructuring and Reform Act of 1998
Effective Tax Administration
As a result of both real and perceived abuses of taxpayers by the IRS, in 1998 Congress passed the IRS Restructuring and Reform Act of 1998 (RRA 98). Part of this Act, and the resulting Internal Revenue Code, setup guidelines where the IRS could consider an Offer In Compromise from the position of Effective Tax Administration.
The IRS under the umbrella of Effective Tax Administration can consider hardship, public policy, and equity when deciding to negotiate an Offer In Compromise settlement with a taxpayer.
The IRS hoped to forster a belief that the tax laws are fair, equitable, and applied to everyone in the same manner.
Effective Tax Administration (ETA) is an option for a taxpayer only after consideration has been give to the other methods by which an Offer In Compromise is considered, Doubt as to Liability (DATL) and Doubt as to Collectibility (DATC).
By rule if a taxpayer asserts an Offer In Compromise under Effective Tax Administration he/she must submit Form 433-A and/or Form 433-B - Collection Information Statement along with the other documentation require for an Offer In Compromise.
The attorneys at www.offerincompromise.com can help you evaluate how to proceed with your Offer In Compromise. Please fill out our Free evaluation.