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IRS expands its offset authority.
- Article from:
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The Tax Adviser
- Article date:
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January 1, 2008
- Author:
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Copyright informationCOPYRIGHT 2008 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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[ILLUSTRATION OMITTED]
The Service has published three revenue rulings and proposed and temporary regulations that expand its ability under Sec. 6402(a) to offset overpayments against tax liabilities and its ability under Sec. 6411(b) to apply tentative carryback allowances against unpaid tax liabilities. The rulings appear in IRB 200737 (9/10/07).
Sec. 6402(a) provides that the IRS may credit the amount of any overpayment against any liability for an internal revenue tax and refund any balance to the person who made the overpayment. Regs. Sec. 301.6402-1 provides that credit may be made against "any outstanding liability."
Sec. 6411 (a) allows tentative carryback ...
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