No. 20-514

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

Lower Court: Fifth Circuit
Docketed: 2020-10-19
Status: Denied
Type: Paid
Response Waived
Tags: contingent-obligations contract-interpretation debt-repayment irs irs-agreement offer-in-compromise payment-terms statutory-obligation tax-compliance tax-payments
Key Terms:
SocialSecurity Immigration
Latest Conference: 2020-11-13
Question Presented (AI Summary)

Whether the Offer in Compromise (OIC) form contains clear and unambiguous language regarding the obligation to comply with tax payments for the next five years

Question Presented (OCR Extract)

QUESTION PRESENTED Where 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? t ;

Docket Entries

2020-11-16
Petition DENIED.
2020-10-28
DISTRIBUTED for Conference of 11/13/2020.
2020-10-22
Waiver of right of respondent Commissioner of Internal Revenue to respond filed.
2020-10-05
Petition for a writ of certiorari filed. (Response due November 18, 2020)

Attorneys

Commissioner of Internal Revenue
Jeffrey B. WallActing Solicitor General, Respondent
Jeffrey B. WallActing Solicitor General, Respondent
Edwrd F. Sadjadi, et al.
Edward F. Sadjadi — Petitioner
Edward F. Sadjadi — Petitioner