Offer in Compromise - Goes to Court

Offer in Compromise - Goes to Court
On Nov. 1, the United States Tax Court handed down another defeat for a pro se taxpayer challenging the collection action of the commissioner. In Wilcox vs Commissioner, T. C. Memo 2005-257 the Tax Court held that the taxpayers vague suggestion of an offer in compromise was not enough to find that the denial of relief at a CDP hearing was an abuse of discretion.

A taxpayer who timely requests a CDP hearing and submits an offer in compromise at that hearing is entitled to challenge the denial of the offer in compromise in Tax Court ( or U. S. District Court if employment taxes are involved.) Wilcox acting pro se was just not savvy enough to have submitted a properly filled out form 433A or Form 656 Offer in Compromise. You can find the full text of the case at my website Offersecretsrevealed.com