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Generally, the program is not available for Collection Appeals Program, Collection Due Process, Offer-In-Compromise, Trust Fund Recovery and others cases out-lined in Ann. IF A TRUST FUND RECOVERY PENALTY IS ASSESSED, the taxpayer can appeal, ask for a collection due process hearing, submit an offer in compromise, pay a representative penalty, file suit, seek reimbursement from other responsible persons or arrange to pay the assessment in installments. The draft procedure would be available for factual issues such as valuation, reasonable compensation, substantiation, transfer pricing, trust fund recovery, and offers in compromise less than $50,000. |
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