Over the years the IRS offer in compromise program has been the subject of a great deal of criticism by Congress, the National Taxpayer Advocate and taxpayer representatives. The new initiative represents the most dramatic liberalization of IRS settlement policies ever announced. It represents a welcome change from an agency which has always placed substantial roadblocks to those seeking to compromise their tax obligations.
From the Government’s perspective, statutes of limitation restrict the taxpayer’s right to claim a refund of
overpaid tax or initiate litigation to obtain a refund. From the taxpayer’s perspective, statutes of limitation
prevent the IRS from collecting a deficiency in tax or beginning a civil or criminal case. In short, statutes of
limitation provide a date of finality after which actions taken by the IRS or the taxpayer cannot be disturbed by