Bankruptcy Taxation Committee

ABI Committee News

New Law Mandates “Pay to Play” Offer-in-Compromise Rules

by Eric L. Pruitt
Baker, Donelson, Bearman, Caldwell & Berkowitz, P.C.; Birmingham, Ala.

The Internal Revenue Service (IRS) offer-in-compromise program has changed significantly following the July 16, 2006 effective date of certain provisions in the Tax Increase Prevention and Reconciliation Act of 2005 (TIRPA). Under §7122 of the Internal Revenue Code (IRC), the IRS can settle or compromise federal tax liabilities with taxpayers in certain situations. An agreement between the taxpayer and the IRS that resolves the taxpayer’s federal tax liability for less than the full amount due is an offer in compromise. TIRPA added a new sub section (c) to IRC §7122 that sets forth the rules taxpayers must now follow in submitting offers to the IRS to resolve tax disputes.

Read the full article.


Letter from David H. Stein, Chair

Dear Tax Committee Members:

I'd like to announce the appointment of Eric Pruitt of Baker Donelson as the newsletter editor for the ABI Bankruptcy Taxation Committee. Eric and I are inviting anyone who wishes to write a short piece or case note (500-1,000 words) on a topic of interest for the electronic newsletter to either contact Eric or myself. Eric may be reached at (205) 244-3836 or epruitt@bakerdonelson.com. We hope to make the ABI Bankruptcy Taxation Committee an active and vital committee for its members. Please share your ideas for committee projects that interest you and that you would be willing to work on to educate fellow committee members.

Best Regards

David H. Stein, Chair
ABI Bankruptcy Taxation Committee
dhstein@duanemorris.com
973.424.2022


Agenda for the 2006 Winter Leadership Conference

  1. Practical Issues and Answers from the Internal Revenue Service Perspective (including an overview of BAPCPA tax changes, an update on centralized insolvency, and a Q & A period)
    Presented by:
      Rachael Zepeda, SBSE Senior Attorney, Chief Counsel, IRS
      (Phoenix); Special Assistant U.S. Attorney, Arizona and New Mexico
      William Unger, IRS Group Manager, Insolvency Division
      (Phoenix)
  2. Offers in Compromise
    Presented by:
      Dennis D. Bean, CPA, CIRO, Dennis Bean & Company
      (Fresno, Calif.)
  3. Hot Topics (as hot as it gets when you combine bankruptcy and taxation in the desert)
    Presented by:
      Christopher Bayley, Snell & Wilmer, LLP (Phoenix)
      Eric L. Pruitt, Baker, Donelson, Bearman, Caldwell & Berkowitz,
      P.C. (Birmingham, Ala.)