Bryan Camp has published an article on the TaxProf Blog, titled “Lesson From The Tax Court: The Concept Of Reasonable Collection Potential”, which discusses the role of Reasonable Collection Potential in law. The article begins as follows:
One key concept for submitting a successful Offer In Compromise (OIC) is something called the Reasonable Collection Potential (RCP). RCP is not a hard-and-fast calculation. It contains lots of wiggle room for savvy taxpayers. But there are limits. Jerry R. Abraham and Debra J. Abraham v. Commissioner, T.C. Memo. 2021-97 (Aug. 3, 2021) (Judge Urda), teaches a very useful lesson in both the extent of, and limits to, the wiggle room in RCP calculations.
Click here to see the full article: “Lesson From The Tax Court: The Concept Of Reasonable Collection Potential.“
Posted by Josh Saret, Associate Editor, Wealth Strategies Journal.