June 2011

Emily Kingston co-authors “Funding Offers in Compromise from the Taxpayer’s Retirement Plans: How Much Is Enough?” in The Journal of Taxation


When a taxpayer with an outstanding tax liability depends on a retirement plan account to cover basic living expenses, it may be difficult to determine how much to offer in compromise of that liability without putting the taxpayer at risk of economic hardship. Factors that must be taken into account include the probability of the taxpayer’s survival and the probability that the retirement fund will not be depleted in the taxpayer’s lifetime.