JM 6-6.430
At times, a taxpayer will submit a compromise proposal directly to the Tax Division in a case handled by the United States Attorney. In that situation, the Tax Division will request the United States Attorney’s recommendation on the offer.
During compromise negotiations and the pendency of the offer, the Tax Division relies on the trial attorney to secure any additional time needed to accomplish the next step in the court proceedings. This protects the Government's interest and permits the Tax Division to take final action on the offer.
[updated April 2018]