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SECTION 9. REJECTING AN OFFER

Internal Revenue Bulletin 2003-36 · 2026-10-03 edition · updated 2026-10-04 · United States

TO COMPROMISE

.01 An offer to compromise has not been rejected until the Service issues written notification of rejection to the taxpayer. Section 7122(d) requires the Service to conduct an independent administrative review before the rejection of an offer to compromise is communicated to the taxpayer. The Service reviews each case to determine if the proposed rejection is reasonable based on the facts and circumstances of the case. Rejection is effective as of the date on the rejection letter. When an offer is rejected the Service will not refund the application fee submitted with the offer.

.02 The taxpayer may appeal the rejection of an offer to compromise to Appeals. The taxpayer must timely file the appeal with the Service office that rejected the offer. An appeal is timely filed if it is delivered to the Service or postmarked within thirty days from the date of the letter of rejection.

.03 Pursuant to section 6331, the Service may not make a levy on the taxpayer’s property or rights to property for thirty days following the rejection of an offer to compromise or while an appeal of a rejection is pending.

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▸Contents — Internal Revenue Bulletin 2003-36
Internal Revenue Bulletin 2003-36

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