Doubt as to liability Clause Samples
Doubt as to liability. Doubt as to liability ex- ists where there is a genuine dispute as to the existence or amount of the cor- rect tax liability under the law. Doubt as to liability does not exist where the liability has been established by a final court decision or judgment concerning the existence or amount of the liabil- ity. See paragraph (f)(4) of this section for special rules applicable to rejection of offers in cases where the Internal Revenue Service (IRS) is unable to lo- cate the taxpayer’s return or return in- formation to verify the liability.
Doubt as to liability. Doubt as to li- ability exists where there is a genuine dispute as to the existence or amount of the correct tax liability under the law. Doubt as to liability does not exist where the liability has been established by a final court decision or judgment concerning the existence or amount of the liability. See § 301.7122(e)(4) for spe- cial rules applicable to rejection of of- fers in cases where the IRS is unable to locate the taxpayer’s return or return information to verify the liability.
Doubt as to liability. If you do not agree that you owe the tax, or if you do not agree that the amount of the tax is correct, you can submit an offer in compromise on the basis of doubt as to liability. You will need to tell the IRS exactly why you do not believe that you owe the tax, or why the amount the IRS claims you owe is incorrect.
