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U.S. v. Tenzer, No. 96-1653 (2nd Cir.) (127 F.3d 222) (September 19, 1997) (Judge Roger J. Miner)

Here the Court held that one of the key components of the Voluntary Disclosure Policy was the requirement that the taxpayer make bona fide arrangements to pay his tax liability - and that a Offer in Compromise was not such a good faith arrangement where the taxpayer offered to pay ...

 

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