IRS can reject Offer In Compromise if taxpayer can afford to pay the full amount

Crawford Pile Driving, LLC v. Commissioner (U.S. Tax Court 2025) Offer-in-Compromise Rejection in CDP Review Summary

The Tax Court upheld the IRS’s levy and lien against Crawford Pile Driving, LLC after finding that the company could afford to pay its full tax debt. Appeals had rejected the company’s $111,077 settlement offer because updated financial records showed it could pay about $2.3 million, and the court agreed that was reasonable.

Holding

The Tax Court granted …