http://ml.csmccord.com/articles.html As tax professionals, we have authored or co-authored tax articles on a variety of topics. http://ml.csmccord.com/'articles/ml-01.pdf A long-standing provision of the Internal Revenue Code has allows the IRS discretionary authority to compromise a tax liability ("OIC") for less than the full amount owed either for doubt as to liability or doubt as to collectibility. An IRS Policy Statement as recent as 1992 places the IRS on record as supporting the OIC program. Congress signaled its support, if not a desire to broaden the offer in compromise program in the IRS Restructuring and Reform Act of 1998. Nevertheless, during recent years there is clearly a wide-spread perception among tax practitioners as well as the National Taxpayer Advocate which holds that the Service is less than committed to the OIC program and that technicians and managers responsible for administering the program appear to be operating under a directive to find ways to reject offers rather than look for ways to help get offers approved. Tax practitioners generally believe that the current Offer in Compromise program is administered today in a way which is inconsistent with clearly expressed Congressional policy which favors a liberalization of the Program. Accordingly, it is recommended that Congress conduct hearings at which Service representatives are called to testify and address the negative perceptions of the Program among tax practitioners and the public at large. http://ml.csmccord.com/'articles/ml-02.pdf In part as a result of the relative decline in the size of the inventory of the United States Tax Court, cases appear on trial calendars much more quickly than they have in years past.