Why might my offer be rejected?

An offer in compromise may be rejected for a variety of reasons. An offer will likely be rejected if the taxpayer:

  • Has the ability to pay the tax liability in full, either immediately or on an installment payment agreement;
  • Has provided insufficient documentation, despite Department requests for additional information;
  • Omitted or undervalued income or assets on the application;
  • Has collected the taxes at issue from customers but failed to remit to the Department;
  • Has a history of regular or willful non-compliance with Tennessee tax laws;
  • Has a history of criminal tax fraud (conviction, guilty plea, or “nolo contendere” (no contest) plea); or
  • Has active personal, successor, or transferee assessments being reviewed for the same tax liability, which can affect the Department’s ability to collect the full liability.
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