Section of Taxation
Submission to the Executive Branch

Contents | Summary | A | B | C | D | E | F | G | H

Comments on the Voluntary Fiduciary Correction Program

  1. Example 10. Treas. Reg. § 301.7430-7(c)(1) provides, among other things, that a qualified offer must be made by the taxpayer to the United States during the qualified offer period. Treas. Reg. § 301.7430-7(c)(2)(i) provides that a qualified offer is made to the United States if it is delivered to the office or personnel having jurisdiction over the tax matter at issue. If the proper person cannot be determined, then the regulations list the persons to whom to send the qualified offer. Example 10 of Treas. Reg. § 301.7430-7(e) provides an example where the Examination Division issued a 90-day letter. The taxpayer timely filed a Petition, and, the next day, mailed an offer to the office that issued the notice of deficiency. That office transmitted the offer to the field attorney with jurisdiction over the Tax Court case. We believe that this Regulation should make it clear that under Treas. Reg. § 301.7430-7(c)(2)(i)(B) the taxpayer could have delivered the offer to the Office of Chief Counsel even if the taxpayer knew the office issuing the 90-day letter. It might also be helpful to identify when, if ever, the office issuing the 90-day letter ceases being the office having jurisdiction over the tax matter.

Contents | Summary | A | B | C | D | E | F | G | H