I just gotta get this memorized. From Internal Revenue Code. Says it all (which, for those of us with state income taxes, gives us an extra bullet for those numbnuts, as well):


<FONT face=Tahoma size=2>Internal Revenue Code
<H2><FONT size=2>Part 4. Examining Process
Chapter 18. Exam Offer-in Compromise
Section 2. Doubt as to Liability Offers</FONT></H2>
<H3><FONT size=2>4.18.2.2 (01-01-2000)
Considering the Liability Issue </FONT></H3>
<DIR>


1.<U>Doubt as to liability exists where there is a genuine dispute as to the existence or amount of the correct tax liability under the law. Doubt as to liability does not exist where the liability has been established by a final court decision or judgment concerning the existence or amount of the tax liability.</U>


Randy</DIR></FONT>