Discussion:OIC Default in 1997, File Another One?
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Discussion Forum Index --> Tax Questions --> OIC Default in 1997, File Another One?
| 26 February 2007 | |
| Hello All,
Client defaulted on an OIC in 1997, and wants to file another one. After research, I cannot find where he cannot file another one. I would say NO, but haven't found a definitive answer. Could someone please point me to the IRC, TR, R.P. regarding this. No Pubs please.... Thank you, Mike | |
| 26 February 2007 | |
| Before you file another, find out the new CSED. He may only have a few months left. | |
Rgtaxservice (talk|edits) said: | 26 February 2007 |
| What's a CSED? | |
| 26 February 2007 | |
| Collection Statute Expiration Date - see the Internal Revenue Manual | |
| 27 February 2007 | |
| I will get the notices from my client regarding the CSED. For now, are there any restrictions on defaulting the old OIC and then filing a new OIC for the more recent taxes?
| |
| 27 February 2007 | |
| I would not request notices from your client on the statute expiration dates as they are highly unlikely to have anything of value. Get records of account from the IRS for all open periods. Any Offer MUST cover ALL delinquent liabilities. As previously noted, nothing should be done until you know exactly what the statutes are for each period since filing an Offer extends the statute.
I have submitted Offers after clients defaulted on other Offers and had them subsequently accepted. | |
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