Contents | Summary | A | B | C | D | E | F
| G | H
Comments on the Voluntary
Fiduciary Correction Program
- Making an Offer Other than in Dollars.
Treas. Reg. § 301.7430-7(b)(3)
requires that a qualified offer must state a dollar amount of the proposed tax liability.
In some cases, the taxpayer might not have the resources available to calculate the tax
liability, or the tax liability might be based in part on facts not yet known. Taxpayers
should be permitted to offer a percentage of an issue, or a dollar amount of income
adjustment. This change would promote settlement by giving taxpayers greater flexibility
in making their offers.
Contents | Summary | A | B | C | D
| E | F | G | H |