DEPARTMENT OF. THE TR£AStJRY
1N'r£RHAL Jt!!VEHt1! s EJtVl et:
WASHtNCllTCH. D.C. ~1J224
MEMORANDUM FOR NATIONAL. TAXPA'fER ADVOCATE
FROM: Eliot D. Fielding. A$sociate Chief Counsel
(enforr=ement- Litigation)
SUBJECT: Au1hcrity of Taxpayer Assistance Orders OVer Appeals
8ACKGROUND:
This responds to your request da1ed August:3, 1998, fur our opinion concsming the
extent of the Taxpayer Advocats's (TPA) a\&thority over the Office of Appeals
- (Appeals). You refet'to one partIr::War case involving a taxpayer who inQrred a
c:::a.sualty loss i n _ but decided not ft.l claim the loss until he ad11alfy incurred the
repair exp~~_a decision appare.....!!!!Lmade with.input from an IRS
appare.....!!!!Lmade
employee. On auCr~ the casJalty ross for_was di~Qwed but 1he taxpayer
was naw time-barred from efaiming ftae rass on h i s " return. The taxpayer P4id
the deffdency and submitted a daim fer reful'1dw eventually endjng up in Appeals.
The Appeajs Officer revfewmg the case recommended tf1at the deficiency be
.reduced by half, essentially sprdftng the difference Wfth the taxpayer, but was
ovenulecf by the Associate Chief at Appeals. The ta:xp~pearedat a tOecil
problem solvfng day and his case was reviewed hy tf1~Taxpayer Advocate
who believed the taxpayer shcu(d have received relief. but was not sure whether he
had authority to issue a Taxpoyer Asslstance Order (TAO) granting the reflef
sought. The ~ A was not able to coordinate the case with the Appeals
representative at the Problem Solving day because the Appeals representative at
the Problem Soivtng wa:a
.E!t. the same Appeals Officer who had been cvefT\Jled.
After c:cnsutting w;th ~istrid Counsel on the potential litigation hazards of the
case, the TPA dedded that it was not appropriate to force the taxpayer to litigation
because of the fow doUar amount and litigatfon risks and so resolved the problem
by foUowing the original Appeals Officers recommendation and. splitting the
difference with the taxpayer.
ISSUES:
You believe that the TI=' A has some authority over Appeals but the extent at that
authority is undear. You ask this office (1) whether the TPA's actions were pro~r
in this partiCJlar case and (2) what optfcns does the TPA have tel help taxpClyem in
2
similar situations when Appeals makes a determination with which the TPA
TPA
disagrees.
CONCLUSION:
It is our vfew 11131 tile refationship between the Office at the T~ayer Advocate and
the Office of Appeals is nat intended to be hierarchical or advers:atfaf in nature but
is instead intended to be coordinate in nature.. E:ac:h office serves as a cheek upon
the various adivitJes of the Setvfce. not as a check upon the other. E3cn pn::Mdes
administrative review and remedies for what are for the most part d"'rfferfng cfasses
at problems which 'taxpayers may encounter with cf'dferent fundions within the
Service; the Office of Appeals is oriented towards substantive. technical decisions
while the TPA is oriented towards intemaJ procedures and the pmeessing of
TPA
taxpayer disputes. That is.. Appeals generaUy sUfves to resolve tedtnic:al .
disagreements the taxpayer may haYe either with the merits of the tax or the
legality of its collection. It prcvides a AMew which ensures that 1f1e Servlce
c::ompUes with the revenue laws boffl in properly determining Ute taxpayer's Rabilfty
(a tax liability determirlation) and p",perly ~Itecting if (a a31JecBcn detennination). 1
The TPA, in ~ generally strives to resoftJe procedUral p",blems the taxpayer
may be encountering in resolving ttre CClOec:tion or setUement of the account
balance. The TPA facilitates the resolution of tmcpayer problems by ensuring that
. the taxpayer receives pro~ process-that ~ proper considet'3tion by the proper
fundioo-without suffering a significant hardship in the meanwtJile. We do net
believe that Congress intended to subject eilher ~ each of whose very
existsnce is to provide incfepenc:ient adrninistr3tiVe review and reUef. to the
. oper.ation of the other. .
Accordingly, we conclude that a TAO may not overturn or modify a tax liahffity
determination made by Appears. Nor may the TPA overturn or mocrlfy a coJlection
deteflTlination made by Appeals or act as a substitute for a caRection detennination
which should be made by Appeals. A:J we explain below, however, there w11J be
times where the changed ciraJrnstances of the ~yer may warrant the TPA's
1 We ccnsic:fer Appeals' role in the Colledion Appeal Process to be part of i1s
technical review function. A CAP review is designed to ensul'9 that the S~ce's
C::J/ledion acticm is within the b to refease property at the taxpayer le~ed upon, or
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I
(2) to cease any action. or refrain from taking any adlcn. With respect
to the taxpayer under
(A) chapter 64 (relating to eoOection),
.
(8) subd1apter B of anapter 70 (refating to bankruptcy and
recetv~hips),
(C) chapter 78 (relating to di:'3cavery of liability and enforcement
01 title). or .
(0) any other pnMslon of Jaw which is specificany described by
the Taxpayer Ombudsman In such order. .
As initially written, section 7811(b) did notgr:mt the Taxpayer Ombudsman the
authority tD detennine. contest or modify a taxpayer's tax liabifrty. This conclusion
fClI1aws from both the statutcfy language and ttl. legislative history. Sedfon
7811 (b) provides that a TAO may require the reiease of levies fn:xn property or the
ceasing of any adicln' taken under three enumer.ated chapters of the Code. None of
adicln'taken
the tftt'ee enumerated d1apters in concern substan1ive ~ matters. Thus, a TAO
could. under ~on 7811 (b)(2)(A). enjoin the Service trom flllng a Notfc:e of
. Federal Tax Lien (NFTLr. under section 7811 {b)(2)(B}.. enjoin the service frnm
{b)(2)(B}..
making immedlate 'as6essments; and, ffnaOy, under sedfon 7811(b}(2)(C). enjoin
the SelVice from issuing, or seeking enfon::ement of, a summons.
At the end of ttlis Ibt at specific chapters and subchap1ets, Congress placed
paragraph (2}(D) which adds to Ule list a catcttafl phrase: Wany other provision at
law which is specifically desc::nbed by the Taxpzjer Ombudsman." The catchall
phrase in section 7S11(b){2)(D) did not expand the permitted content of a TAO to
technical, or SlJbstantive, tax matters. To begin wittt. the phrase "any ather
provision of raw- cannot mean literaUy mrt provision of Jaw. If it were so read~ there
wcuJd be no reason for C:lngress-tli h3ve listed the specific previsions In
paragraphs (2)(A) ltIrough (2)(C); the enumeration would serve no purpose. In
construing statutory meanings, it is weU est:abJished that one part of a statllte
shOUld not be interpreted irl such a way as m render another part meaningless.
See Connecticut Nat'f Bank v. Gennaro, 503 U.S. 249,253,112 S.ct 11.0«;., 1149
(1992)\courts should dfs{avor Interpretations of statutes that render language
superfluous); Mountain States Telephone & T!}legrnph Co. v. etlfblo of ~;1nta Ana..
Ana..
472 U.S. 237. 249-50, 105 S.Ct. 2581,2594-95 (1985) (N'e of statutory
constnJction requires statute to be interpreted so fhat it does not render another
provision a nullity). .
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When language in a stat1rte cannot be construed litercdly, canons of staUrtory
CQnstruction may aid in its proper intefpretatfon. ~ete. the guide for the praper
interpretation of paragraph (2)(0) is fcund in the well-settled principle that a genera)
catchall phrase which follows a specif.ic list of iteins 18 -construed to embrace only
objects similar in nature to those obj~ enumerated by the preceding sJ:]ecific
wcrd$.· 2A Sutherland. Statutory Construction (1992 ed.) § 41.17 n.4. This
principle at ejy;;dem generis is routinely us4i:d to ccnstrue statutes.. induding the
Code. ~!t..9a. United States v. Weidon, 145 F.3d 158 (3"' Cir. 1998); ~
Analysts v. I.R.S .. 117 F.3d 607 (D.D.C. 1997) (appiying ejusdem generis to
I.R.S..
construe the tsJm -data- in lAC. § 6103(b)(2)(A».
Based on mUZ'em Sener;$, 1tte catd1af1' phrase in sec::tJon 7811 (b)(2)(O) is best I
construed as beh1g limited to 'other provisigns of law IiJce the ones enumerated in
Ute statute. The c:cmmon ~ at the enumerated .statutes is that they all
~ concern the Procedl'~ by which the Servlaa detetmines and collects 1f2e taxes due
and owing. None cencem the actual. substantive defarmindan of iax. Indeed. 1tley
an f:aJ1 under subtitle F of trle Code, which is tilled "Pracedute and Admini.str"aOOn.·
Thus., the bT'eadth ofttle c:atd1aJ1 phrase in sectfon 7811(b)(2)(O) is nmited fa similar
types af statutes wiCtlin Ute Internaf Revenue Cod8p that is. statutes which govem
the process by which the Service determines 1axes 8m:! the process by which 'the
. SetVfce ooUects the taxe3 due and ewing.Z •
This interJ)retaticn bas been inc:arpotated lntO 1tle implementing regulation" Treas~
Reg. § 301.7811-1. promulgated on M4ilrctl 21, 1989, and modified on March 20,
1992. Tre3S. Reg~ § 301.7811-1(c)(1)(ii)(O) praVfdes that a TAO may address -any
other section at the Internal Revenue Code undet' 'Nflich the Internal ~evenue
$entice is takfng' or is abOut to take administr
C3USes or'Mll cause a significant hardship.~ The regulation further provides, in
subsedion (c)(3). that a TAO "WfO not be Issued to contest the merits of any tax
liability ncr is a taxpayer assistance order Intended iD be a substitute for Qr an
additi0'1 to any esf2b{ished administrative or Judicial review procedure. laS Thus. for
,
Sedion 3401 of ftJe recentty passed IRs RestzudlJring ~ Refonn Act. P.L
%
105-205 (July 22, 1998), authorizes the Offlce of Appea£s to 1'e'Jiew. upon ~
request, the appropriateness of certain pt'CpQSeC1 oolfedion actIol1$" We disoJss the
interpJay between this grant of authority and section 7811 below.
~ Subsection (cX3) at the regulation prmides ttlat"A taxpayer Cissistance order
(C:OtJtfllUed._}
5
exam~(e. if there is an 'already esta~ist1ed admirdntlve review procedure. the
TPA is not authOrized to pmvide a second substantive adrnlnistraCfve r"Mew. ncr
does tile TPA's review alter the results of any estabBshed admlnisba1ive or judicial
review pr~ure..
This interpretation at section 7811(b)(2)(C) js also supported by the legislative
history at section 7811. When enacting the original statute, Ccngress was well I
aware that the Taxpayer Ombudsman did not hC1Ye ihe authority to change a
technicat decision. Conference Report on 1he Tec:tlnlcaf and Miscelaneous
Revenue Act of 1988 (TAMRA), H.. Rep. 100-1104, at 215. There was no incfication
that Congr:ess'intended to give U1e Taxpayer Ombudsman the ability to overturn a
technical detennination of the taxpayer'!; habiDty. To the o::1n~. the only
expressed intent of the original bDJ was to give the Taxpayer Ombudsman an ability
to -require remecfic11 actions, such as refeue from levy of property c.f the taxpayer.·
.!d.
As originally wrifIen. sec:tion 7811 (b) aflowed TAOs 10 resfraln the Service from
taking advef$e adions pen~ing resolUtIon of 1he tilXpayel'$ probfem but did net
eXpti.citly authoriZe TAOs to order 1tie SSrvfce tD take positive actions to relieve
taxpayer hardship. Far exampfe. wtIDe a TAO eould require U'1e Service 11:1 forbear
filing an NFTI... it cau'd not requlre the SeM~ fD ."lease an NFTL if already tiled •
tiled•
. This gap was first remedied by administrative prac::tfc::e in Delegation Order (00)
239 (01-31--92) Which delegated to the Taxpayer Ombudsrnallr as well as to other
fundion$ (but nat to Appeals), Ute authority to issue TAOs on Issues not specifically
) (_continued)
may generally not be issued....fD enjoin an act of 1he Oflfce of Chief COUnseJ (with the
issued....
exception of ~peab)... This p~icR does n« authorize a TAO 10 modllY or. overtlJm
an Appe3Js detErmination, espedatIy since this language oomes just t:efcre 1he
language quoted in 1tle text.. The reason why a TAO would generaUy not be appropriate
to enjClin an act of Counsel is becaUse section 7811 authorizes TAOs to provide re'et
from the way the fntemaJ revenue laws'are "being administered: On the one hand.
Counsel generally does not adminlsterihe ~tutes; it instead litigates cases, provides
frtigation support to ti1e Department of Justrce, and provides advisory interpteta50ns of
the raw to both the Serva and ihe public. Appe:aIsw on "the ether hand, does administer
the law in that Appeals makes substarttive tax detenninatons and Issues notices of
deficiency. At the tfme the regutationwas wri:tten, Appeals was a part of the Offlc:e of
Chief Counsel. That is why the reguladan is warded _ it is. ThUs, while a TAO may
order Appeals ~ithin a spec:itfed time ~ to perrorm its revieW ftJrJdfon, l.R.C.
§ 7811 (b), it may not revieW or change the detemtinafion once maqe.
7
covered In sedicn 7811 but whic&'l invofved a significant hardship 1J2at the SeMc8
could relieve. Oef~on Order 235 allowed TAOs to A!.qUire pasftlve ads, such as
maJdng manual refunds or expediting ccnsideatfcn of a 1axpa~s problem.· In
1996 Congress incorporated ihis admfnisfratJve S'radfce IntlO the Taxpayer enr of
Rights If (TEOR n). P.L 104-168. mOR II revised section 1811 by renaming the
Ta:qYcIyEf Ombudsman the T~r Advocate and inc:ccporated the abcJve
administrative prndfce by adding. the 1bUowing itaJicized phrase to subsecticn (b )(2):
(2) to cease any action. fake any action as permit1ed by 18Wr or retr3in from
taJ
As with the original section 7811. n~er lf1e revised text or its fegf.sfatlYe history
suggest that a TAO would address 1he merits of a tax detennination. Fi~. as to
the text. Congress did not roodifY paragtaplts 781 ~'b)(2)(A} thmugt-. (0): Therefore
the interpretation dk:tated by the principle of ejusdem generis and incorporated into
• Treas.. Reg. § 301.7811-1 stiU appfies:. The change made ~y Congress-addtng the
phrase ~ any actIon as pennitted by law'" was induded so as fa aDew TAOs to
order the SeMce fa take posiUve adions. and not simply prevent the Service *om
taking adaMS. But the actions still had to be ones permitted by the erwr:nerclted
• 00 239 delegates to Regional Carnmis:sicnets. District and ~ Center
Directors and Assistant Dired.crs and others, fndudJng the TPA. ~e authority 10 issue
Tmcpayer Assisf:a11Ce O~en; on i$sues net specfflcatly c:oveA!d in ._ secfion 7811_. but:
which involve a significant hatc!ship tf1at the IRS can relieve.._ .• 'Nhle ibis language
may ~pear very broad. it is DO~ as cao be seen by a:m~rin9 itwith DO·No. 193 (Rev.
the
5) {8-2S-96}, whldl delegates'1I::i D~ cOmrniSmcner all of ttie Corlvnissioner's
authority to -perform any function ihe Commissioner is autfIorized tD peOOtm. • We do
peOOtm.•
not read ttle reference to sedJon 7811 in 00 239 as authorizing TAOs to modify or
rescind substantive decisions regarding'tax JiabiliHes.. MIst. to do $0 wourd aeate a
conflict between the 00 and the Trvasury Regulation which ecpflc:if1y forbids TAOs to
contest technical detenninafions.. SeCond, the DO can l'ea$Onabfy be read in harmony
with the regulation. The reference to '1ssUes not speeificaIIy cavered in ._ section 7811
was n~ry becmse when the r1!gtJlatfon was 'Mitten section 7811 (b)(2) .afIowed
TAOs only to enjoin ads (and rel~ levies). Thus.. any issue which requited a
positive act to refieye the ~s hardship would lie oufsfde the fssues spedftcany
covered by section. 7811. ~ird. the ~pfes of issues gNen in the 00 support this
interpretation of the reference to "lSStIe'J not spedfic:aIJy covered in _. section 7811.·
All of the examples in the 00 are concerned with process; they reccgnize the TPA'S"
31..1hority to aid the taxpaye- by ensurittg 5mefy revtew by the appropriate function.
None suggest that the TPA may per1brm technical or substantive ~ .
8
statutes or any other like statute. Seccnd. as to the legislative history, the
Conference Report on TBOR. II. H. Rep.. 104-606, explains that ttae reasons for
changing 1119 law w:as that it was undear in certain situations whether the T~er
Ad'Iocate had authority to issue a TAO. The examples used in the Conference
Report all concern process issues. For example, the Report identifies one problem
as being that "'1he IRS Collection OMsian may take an enforcement action when the
taxpayer has had no actual notice of the deficienCy and is I10t affon:Ied any
opportUnity fa obtain an administrative review of the V31idity of ttle tax deficiency.
Significant!y. the Conference Report does m!t then go on tD say that the remedy for
this pJ:'Oble",? is fer 1I1e TPA ~ provide Ute miS$ing. substantWe.admfnistrative rettiew.
Instead. the Con(entnce Report says that'wttat is expanded is the TPA"s authority
"to temporarify stay the IRS coUectfon adfon in order to allow for a review of the
appropriateness ar the proposed action." There is no indication that the TPA would
then have any authority to ovemJ'e the decision as to the appropriateness of the
O){1ectian action. What the Conference Report descnbes is 1hus 1he established
admini.:strative practice of aJlowfng TAOs both to order adverse actions stayed and
to order another fundion to affirmatively perform ills ftJnct!Gn (such as issuing or
reissuing refunds due to the taxpayer or determining the appraprfateness at a
collection action) on an expedited basis as to a particnSar taxpayer. .
Thus. based an the history of section 7811 and its ~ we do not beUeve
,that TAOs can be issued to dispute the merits of a tax determinafion or to preempt
or ovem.Jfe the resutts of an established adminisb'ative or judJdaf revfew procedure.
Inducfing the ~eaI:s pmgrams for examinafion and coJfection review. TAOs
instead can exped"rte nClrmal review processes and ottlerwfse give speciaf relief to
taxpayers caught up in a system wtiose ncmnal operating procedures cause
signific:ant hardship fur t21e taxpayer.
The most recent chapter in this legisfative story. the Restructuring and Reform Act
(RRA), reinfcrces this view. While nothing In ttle RRA diredfy affects the scope of
TAO authority under section 7811(h), two provis:~ns in the RRA illustrate
Congressional determination that·tmpayers have access to various fora within the
service to reso4ve 1heir problems and. demonstrate that for tBchnlcal determinations
Congress chose Appeals as'the p'reper forum. The first prevision, R~ § 11 02(c),
re"ises l.R..e. § 7811(a} tQ provide for greater taxpayer access to the T~ayer
Advocate's office.. The second provision. RRA § 3401, provides fer greater
haxpayer 3ccess to Appeafs. We shan briefly discuss eadt one.
First., RRA § 11 02(c) lowers the threshold for ~payers to apply for a TAO. Prior to
the RAA a taxpayer could not apply for a TAO unless sufferfng or about to stiffer a
·signiflc:ant hardship.· a term nat defined in "(he statute. The RRA beth defines
9
-significant hardship" and ajso u,pands the TPA's authority to issue TAOs to
situations where 1here is no significant hardship but "'the taxpayer meets such othef'
requirements as are set fcrth in Algulatfrms prescribed by the Secretary.· RRA
§ 1102(c). The ccnference report $Uggests that tt1e regulations are intended to be
based on principles of eqUity. so that 1he TP-" may consider tem~ relieving a
taxpayer from tf1e o~on of the internal revenue Jaws, everr when the tmepayer
Wllf suffer no significant hardoSnip. if ether principles of equity would faver reViEW of
the taxpayer's situation. Thus. although the law dearly aUsmpts 11:1 inaease the'
number ot taxpayers fer whom tbe issuance of a TAO coukf be ccnsfdered.. it does
nothing to expand the scope of a TAO and does not after or amend the 'regUlation' s
'regUlation's
prohibition against usirlg a TAO to contest the merits 01 a tax or to substitute for
established adrnini3tratlve and judldaJ review proc:essea
I
Seccnd t RRA § 3401 prevfdes t.:axpeyers ttle right to be heard befot8 the Office at
Appeals wftbin 30 days of being tald that the S«vice has fil'ed an NFn. and wfthin
30 days after being tcld 1I1at the SeMce plans to levy tt1e taxpayers property or
rights to prcperty. The OfIce 01 Appeals is charged with ensuring (1) that the
Service has camplied with appllc:abJe raws. (2) that the tDpayer has an ClppoliUnity
to raise any issue r8fevant to the ccffedfan adJon., mduding a dispute on the merib
of the liabirdy SQught to be c:cllec:;ted if the taxpayer ~QWS that a notice of
de'ffdency whk:h shoUld have been received was not actIJalJy received. and (3) that:
.the proposed collection adIcn balances 1tIe need fof efficient cc'fedion of iaxes
with the legitimate aJncems of the taxpayer that the! c:oUedion adicn be no mere
intruslve than necessary. The ~ auUtority tc ,detennlne the appropriateness
af the cclledion adfcns desaibed in sections 5220 and 6330 Is ledged in Appeals.
not the TPA- Whale the TPA is authcrt2ed to enjoln:1he filtng of NF11..s and the
service of revies, the TPA may net SO enjoin simply because Ute TPA disagrees I
TPA
with the substantive determinClticn made by Appeals. The TP A may not accomplish
indlredty what he has no authority to ac::compfish directly.
CoUedion determinations made by Appeals are, however, different tt1an tax liability
determinations in that aU the facts.necessary to determine a taxpayer's tax have
already occurred at the time the liability detennfnatfon is made, while the
ciraunst:ances which make a partradar coltectfon action appropriate at one point in
time may change. Congress reccgni:'z:ed this in section 3401 of the RRA by
providing for Appeals to retain Jurisdiction over a:JllecU
under Ulat st.rtute. In other SituaU~ however.. the.taxpayer may need the TPA's
however..
help to adjust the c:olledi
circtJmstances. Fat' example. it an fnstaUl1'1erU agreement rs terminated by the
Service under lAC. § 6159, the taxpayer ha=i the opportunity to request a hearing
in Appeals to alScuss 'tl'1e s~on. If Appeals ~ s the termination .. the TFA
termination..
10
may not overturn or A!~ that collection determination. The fact that Appeals'
has, at one point in time, sustained a termination at an installment ag. eement.
however, does not preclude the TPA from dedding whether. if the tbpayet's
clralmstances change. it would be appropriate ~ arrange far another instaRment
agreement for the taxpayer.
Taxpayers who are encountering ,diffiClJlties should be directed to the office that is
most apprcpriate far 1heir problems. tf a taxpayer has a substantive disagreement
wittI an assessed or proposed tax or With the validity of cettain proposed collection
actions, the taxpayer should be able fc obtain 'an independent adminisb-ative
judgment through Appea~ if a ~ayer is encountering problems either in
obtaining that independent judgment or in dealing with the routine or general
correction and ae:countfng processes, the taxpayer should be able to obtain the
assistance of Ute TPA who can either help the taxpayer 1hnxtgh the Problem
Resolution Program or else issue Drders tailored to the 1axpayer's circ:umstanc::es
through the TAO program if the taxpayer is suffenng a sfgntftcant hardshfp or meets
such other requirements as may be written in the regulations to justify special
processing.
We recognize" hawever. that the TPA may not always agree with a technJcaJ I
determination made by Appeals or by another 1lmdfon. In such cases the TF'A can
another1lmdfon.
, stop enfcrced collectmn activity pending a review by the appropriate function to
ef1Sure that tf\e Servfce has c::omprted with all lega and procedural requirements.
The T?A can thus facilitate the administrative revieW process to ensure compliance
with the letter and Jittent of the tax Jaws while not itself assumlng the role of
decision-maker as weil as facirdator. .
The ca$e whid1 prompted your request for adVice serves as an example. The
taxpayer here secured an independent administrative l'e'liew of his proposed tax
liability from Appeals. It was not for the TPA. however, to overrule Appeals'
decision as to the taxpaye~s Rability. Not' was it far counsel to do so, since the
case was still under the jurisdidfon 01 Appeals.. Neither tf1e TPA nor Counsel had
the authority to compromise or settie 1he case.. This does not mean tf1at the TPA
could not aid the taxpayer through the TAO program, however, assuming the
TPA
taxpayet met the TAO program requirements.. The TPA could. for exampCe. (1)
have requested AppeaJs to reconsider or, in appropriate circumstances, elevate the
matter up the chain of command" or (2) arranged fer the taxpayer to submit an offer
TPA
in compromise, if the TPA detenninated that was the appropriate relief.
;
11
We we re hap py to ass ist you in
this ma tter and hop e this me mo
add res s you r que stio ns and con ran dum adequat~y
cerns. rf you hav e any qU est iClM
ple ase con tac t eith er Law ren ce or comments.
202 .a2 2-3 630 . or
H. Sch attn er Bryan T. Camp of 1his offi ce, at
cc: Off ice of AppeaJs