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Form 870 Escondido California: What You Should Know

This question had arisen as follows: Q. Under section 2674(B)(2)(A) of the Internal Revenue Code of 1986, when a taxpayer accepts the IRS' offer of Waiver of Restrictions on Assessment and Collection, the tax imposed under the Tax Code shall be reduced. What happens if the Waiver of Restrictions on Assessment and Collection is rejected by the IRS? A. (1) If a taxpayer accepts the IRS' offer of Waiver of Restrictions on Assessment and Collection, the Tax Commission shall impose a tax equal to the waiver amount. (2) As a result of rejecting the IRS' Offer of Waiver of Restrictions on Assessment and Collection, the Commissioner is authorized to assess a tax equal to the Tax Commissioner's budget estimate of the Tax Reform Act of 1986, effective for the fiscal year in which the Notice of Acceptance is made. In other words, if the Commissioner budget estimate is less than the Tax Reform Act of 1986 tax, then the Tax Commissioner is authorized to assess a tax equal to the Tax Commissioner's budget estimate of the Tax Reform Act of 1986 tax.  — CCH Interconnect (I'm a tax attorney, not a taxpayer. This was just more information I came across in my research into this topic.

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