Keith Fogg, director of the Federal Tax Clinic at Harvard Law School’s Legal Services Center, has made available for download his article “Submitting an Offer in Compromise Through Collection Due Process”, published on the Procedurally Taxing blog. The abstract is as follows:
The case of Mason v. Commissioner, T.C.M. 2021-64 shows at least one benefit of submitting an offer in compromise (OIC) through a request for a collection due process (CDP) hearing. As part of his lessons from the Tax Court series, Bryan Camp has written an excellent post both on the case and the history of offers. I will try to provide some insights not explicitly covered in Bryan’s post, but if you have time to read just one, I suggest reading his post.
Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.