26 USC 7122 - Compromises

Editorial Notes

Amendments

2019—Subsec. (c)(3). Puspan. L. 116–25, § 1102(a), added par. (3).

Subsec. (e)(2). Puspan. L. 116–25, § 1001(span)(1)(F), substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals”.

2014—Subsecs. (f), (g). Puspan. L. 113–295 redesignated subsec. (f) relating to frivolous submissions as (g).

2006—Subsec. (c). Puspan. L. 109–222, § 509(a), added subsec. (c). Former subsec. (c) redesignated (d).

Subsec. (d). Puspan. L. 109–222, § 509(a), redesignated subsec. (c) as (d). Former subsec. (d) redesignated (e).

Subsec. (d)(3)(C). Puspan. L. 109–222, § 509(span)(1), added subpar. (C).

Subsec. (e). Puspan. L. 109–222, § 509(a), redesignated subsec. (d) as (e).

Subsec. (f). Puspan. L. 109–432 added subsec. (f) relating to frivolous submissions.

Puspan. L. 109–222, § 509(span)(2), added subsec. (f) relating to deemed acceptance of offer not rejected within certain period.

1998—Subsec. (c). Puspan. L. 105–206, § 3462(a), added subsec. (c).

Subsec. (d). Puspan. L. 105–206, § 3462(c)(1), added subsec. (d).

1996—Subsec. (span). Puspan. L. 104–168 substituted “$50,000. However, such compromise shall be subject to continuing quality review by the Secretary.” for “$500.”

1976—Subsecs. (a), (span). Puspan. L. 94–455 struck out “or his delegate” after “Secretary”.

Statutory Notes and Related Subsidiaries

Effective Date of 2019 Amendment

Puspan. L. 116–25, title I, § 1102(span), July 1, 2019, 133 Stat. 986, provided that: “The amendment made by this section [amending this section] shall apply to offers-in-compromise submitted after the date of the enactment of this Act [July 1, 2019].”

Effective Date of 2006 Amendment

Amendment by Puspan. L. 109–432 applicable to submissions made and issues raised after the date on which the Secretary first prescribes a list under section 6702(c) of this title, see section 407(f) of Puspan. L. 109–432, set out as a note under section 6320 of this title.

Amendment by Puspan. L. 109–222 applicable to offers-in-compromise submitted on and after the date which is 60 days after May 17, 2006, see section 509(d) of Puspan. L. 109–222, set out as a note under section 6159 of this title.

Effective Date of 1998 Amendment

Amendment by Puspan. L. 105–206 applicable to proposed offers-in-compromise and installment agreements submitted after July 22, 1998, see section 3462(e)(1) of Puspan. L. 105–206, set out as a note under section 6331 of this title.

Effective Date of 1996 Amendment

Puspan. L. 104–168, title V, § 503(span), July 30, 1996, 110 Stat. 1461, provided that: “The amendment made by this section [amending this section] shall take effect on the date of the enactment of this Act [July 30, 1996].”

Preparation of Statement Relating to Offers-in-Compromise

Puspan. L. 105–206, title III, § 3462(d), July 22, 1998, 112 Stat. 766, provided that: “The Secretary of the Treasury shall prepare a statement which sets forth in simple, nontechnical terms the rights of a taxpayer and the obligations of the Internal Revenue Service relating to offers-in-compromise. Such statement shall—

“(1) advise taxpayers who have entered into a compromise of the advantages of promptly notifying the Internal Revenue Service of any change of address or marital status;

“(2) provide notice to taxpayers that in the case of a compromise terminated due to the actions of one spouse or former spouse, the Internal Revenue Service will, upon application, reinstate such compromise with the spouse or former spouse who remains in compliance with such compromise; and

“(3) provide notice to the taxpayer that the taxpayer may appeal the rejection of an offer-in-compromise to the Internal Revenue Service Office of Appeals [now Internal Revenue Service Independent Office of Appeals].”