New Jersey Administrative Code
Title 18 - TREASURY - TAXATION
Chapter 33 - CLOSING AGREEMENTS AND COMPROMISES
Subchapter 2 - COMPROMISES
Section 18:33-2.3 - Effect of compromise agreement

Universal Citation: NJ Admin Code 18:33-2.3

Current through Register Vol. 56, No. 18, September 16, 2024

(a) A compromise agreement relates to the entire liability of the taxpayer (including taxes, ad valorem penalties, and interest) with respect to which the offer in compromise is submitted and all questions of such liability are conclusively settled thereby. Specific penalties, however, shall be compromised separately and not in connection with taxes, interest, or ad valorem penalties. Neither the taxpayer nor the State shall, upon acceptance of an offer in compromise, be permitted to reopen the case except by reason of the following:

1. Falsification or concealment of assets by the taxpayer;

2. Mutual mistake of a material fact sufficient to cause a contract to be reformed or set aside; or

3. The significant change in the financial condition of a taxpayer with which the Director has entered into a compromise agreement.

(b) However, acceptance of an offer in compromise of a civil liability does not alter or affect a criminal liability, nor does acceptance of an offer in compromise of a criminal liability alter or affect a civil liability.

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