COMMENT: Procedurally, the IRS issues a NOD (also known as a SNOD) before it can officially assess the additional tax. Once assessed, the IRS can bring all its collection powers to bear.
COMMENT: One has the right to request a hearing (called a Collection Due Process hearing) in response.
COMMENT: There are three flavors of offer in compromise. The one we are talking about is when there is substantial doubt that the assessed tax is correct. At $1, that is exactly the point Kearse was making.
NOTE: We will come back to the importance of a “stipulation” in a moment.