Internal Revenue Code (IRC): Title 26 of the United States Code containing provisions regarding tax liability, penalties, interest, and rules for settlements and compromises (Section 7122)
Treasury Regulations: Federal regulations interpreting the IRC, including procedural requirements for tax settlements and Form 656 (Offer in Compromise) requirements
State Tax Laws: State-specific tax codes and settlement procedures that may apply if state taxes are involved in the settlement
Statute of Limitations: IRC �� 6501 establishing general 3-year statute of limitations, extended periods for substantial understatements, and Collection Statute Expiration Date (CSED)
Taxpayer Bill of Rights: Framework outlining taxpayer rights during settlement negotiations, including disclosure requirements and appeal rights
Administrative Procedure Act: Federal law governing government agency procedures and administrative appeal rights in tax settlements
Tax Court Rules: Procedural rules governing Tax Court proceedings and stipulation of settled issues when court involvement exists
Contract Law Principles: State contract law requirements including consideration, capacity to contract, and enforceability provisions
Confidentiality Laws: IRC �� 6103 and related provisions governing tax information confidentiality and privacy protections
Professional Responsibility Rules: Circular 230 requirements for tax practitioners and state bar ethics rules governing professional conduct in tax settlements
