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What are the proposed offer terms that became effective as of July 16, 2006?

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What are the proposed offer terms that became effective as of July 16, 2006?

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Taxpayers filing offers (excluding doubt as to liability offers) will 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 fewer 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 offer 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.

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