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Case: Tax Court Has No Jurisdiction to Refund TIPRA Payment Made as Part of Offer in Compromise (9th Cir.) (IRC §6320)

Jan. 25, 2023, 5:00 AM

Tax Court did not have jurisdiction to refund Taxpayer’s TIPRA (Tax Increase Prevention and Reconciliation Act (TIPRA) of 2005, Pub. L. 109-22) payment (requiring a taxpayer who makes an offer in compromise (OIC) to submit a payment of 20% of the value of the OIC) because the power to refund had not been specifically granted to the court by any statute; and as part of the OIC process, the taxpayer acknowledged that he understood that under TIPRA, the TIPRA payment would not be refunded if the OIC was not accepted, the Ninth Circuit Court of Appeals held, affirming the Tax ...