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Comments on the Voluntary
Fiduciary Correction Program
- Relationships with Other Court or Administrative Proceedings.
In making the
comparison of the amount of the qualified offer and the amount of the judgment discussed
above, Treas. Reg. § 301.7430-7(b)(2) provides that "[t]he taxpayer’s liability
under the last qualified offer is calculated without regard to adjustments to be fully
resolved, by stipulation of the parties, through any other pending court or administrative
proceeding." (emphasis added). We recommend that the types of proceedings
contemplated by the phrase "any other pending court or administrative
proceedings" be described with more particularity and that examples be provided.
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