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.