What time period has been established by TIPRA in relation to declaring offers accepted?
IRC 7122(f), as amended by the TIPRA legislation, will cause the IRS to deem an offer “accepted” if it is not withdrawn, returned or rejected within 24 months after the IRS receipt date. If a liability included in the offer amount is disputed in any judicial proceeding, that time period is omitted from calculating the 24-month time frame.