Keith Fogg, director of the Federal Tax Clinic at Harvard Law School’s Legal Services Center, has made available for download his article “Suspension of Statute of Limitations Due to an Offer in Compromise”, published on the Procedurally Taxing blog. The abstract is as follows:
In United States v. Park, 128 AFTR 2d 2021-6390 (2021), aff’d 128 AFTR 2d 6394 (2021) the magistrate judge, sustained by the district court judge, grapples with the statute of limitations on collection and whether the IRS has timely brought a suit to reduce a liability to judgment. The court determines that the IRS brought the suit timely because of the submission of an offer in compromise by the taxpayer. The case provides the opportunity to discuss not only the way the statute of limitations works in this situation but things taxpayers should consider when deciding to file an offer in compromise.
Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.