Ezel / IRS Rulings / 201052015

CCA 201052015: An offer-in-compromise regulation did not permit a dollar threshold

Number
201052015
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Offers in Compromises
Topics
Procedure, penalties, and administration
Code sections
§ 7122
Ruling dated
August 24, 2010
Publicly released
December 30, 2010
Source
View Official PDF

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This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2010, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2010
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel Advice considered whether a dollar threshold could be used under the offer-in-compromise regulations. The advice states that no dollar threshold is permissible under Treas. Reg. § 301.7122-1(f)(3). The brief conclusion addresses the limits on setting such a threshold in the IRS compromise process.

Ruling snapshot

  • Question: Does Treas. Reg. § 301.7122-1(f)(3) permit a dollar threshold for offers in compromise?
  • Outcome: Advice given
  • Key authorities: Treas. Reg. § 301.7122-1(f)(3)

Full text (IRS public release)

ID: CCA_2010082416102050 Number: 201052015
Release Date: 12/30/2010
Office: ----------
UILC: 7122.00-00

From: -----------------------
Sent: Tuesday, August 24, 2010 4:10:22 PM
To: -----------------------------------------------------------------------------------
Cc:
Subject: RE: Redefine RCP questions ---------

I don't think any $ threshold is permissible under section 301.7122-1(f)(3).

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