Caleb’s excellent series on the provision that causes offers to age into acceptance has resulted in the receipt of an actual offer acceptance letter based on the IRS failure to accept or reject an offer with 24 months of submission. With permission from Abe Warshenbrot, we are attaching the correspondence he sent to the offer unit requesting it grant his client’s offer based on the passage of time and the offer acceptance letter he received. His letter might serve as a model for anyone in this situation. The letter from the IRS proves that at least once in the pass couple decades someone has benefited from this provision.
Legal Tax Blog
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Leslie Book
Professor Book is a Professor of Law at the Villanova University Charles Widger School of Law. Read More…
Keith Fogg
T. Keith Fogg is a Clinical Professor of Law at Harvard Law School where he started a tax clinic in 2015. Prior to joining the faculty at Harvard, he began his academic career at Villanova Law School in 2007 after working for over 30 years with the Office of Chief Counsel, IRS. Read More…
Christine Speidel
Christine Speidel is Associate Professor and Director of the Federal Tax Clinic at Villanova University Charles Widger School of Law. Prior to her appointment at Villanova she practiced law at Vermont Legal Aid, Inc. At Vermont Legal Aid Christine directed the Vermont Low-Income Taxpayer Clinic and was a staff attorney for Vermont Legal Aid's Office of the Health Care Advocate. Read More…
Stephen Olsen
Stephen J. Olsen’s practice includes tax planning and controversy matters for individuals, businesses and exempt entities for the law firm Gawthrop Greenwood, PC.
Nina Olson
Nina E. Olson is the Executive Director of the Center for Taxpayer Rights, a 501(c)(3) organization dedicated to advancing taxpayer rights in the US and internationally. She served as the National Taxpayer Advocate from March 2001 through July 2019. Read More…
Samantha Galvin
Samantha Galvin is a Clinical Professor of Law and the Director of the Federal Tax Clinic at Loyola University Chicago. She previously taught and directed the LITC at the University of Denver for more than nine years. Professor Galvin has taught tax controversy representation, individual income tax, and tax research and writing. In the FTC, she teaches, supervises and assists students representing low income taxpayers with controversy and collection issues. Read More…
Caleb Smith
Caleb Smith is Associate Clinical Professor and the Director of the Ronald M. Mankoff Tax Clinic at the University of Minnesota Law School. Caleb has worked at Low-Income Taxpayer Clinics on both coasts and the Midwest, most recently completing a fellowship at Harvard Law School's Federal Tax Clinic. Prior to law school Caleb was the Tax Program Manager at Minnesota's largest Volunteer Income Tax Assistance organization, where he continues to remain engaged as an instructor and volunteer today. Read More…
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