What are the proposed offer and terms that would be in effect as of July 16, 2006?
A4. Taxpayers filing offers (excluding doubt as to liability offers) would have to specify whether they are filing a lump sum or periodic payment offer. The new IRC 7122(c)(1)(A) subsection requires that a taxpayer filing a lump sum offer must pay 20 percent of the offer amount with the application. A lump-sum offer means any offer of payments made in five or less installments. The new IRC 7122(c)(1)(B) subsection requires that a taxpayer filing a periodic payment offer pay the first proposed installment payment with the application and pay additional installments while the IRS is evaluating the offer. A periodic payment offer means any offer of payments made in six or more installments.
