Edward F. Sadjadi, et ux. v. Commissioner of Internal Revenue

Wlier© the IRS argues that the Offer In Compromise (OIC) form the petitioners used was clear and unambiguous, does the OIC form contain clear and unambiguous language that concisely, specifically and explicitly states whether the obligation to comply with tax payments for the next five years is or is not contingent on early full payment of the amount in the compromise agreement before the end of the five-year period? Unlike all common debt repayment agreements where the contract is terminated and all parties’ obligations end when full payment of the agreed-upon balance of the debt is paid, can the IRS impose uncommon conditions upon taxpayers without explicitly and clearly communicating those uncommon conditions?