New York Codes, Rules and Regulations
Title 20 - DEPARTMENT OF TAXATION AND FINANCE
Chapter XIII - Compromises
Part 5000 - Compromises Under Subdivision Eighteenth-a Of Section 171 Of The Tax Law
Section 5000.2 - Effect of compromise agreement

Universal Citation: 20 NY Comp Codes Rules and Regs ยง 5000.2
Current through Register Vol. 45, No. 52, December 27, 2023

A compromise agreement relates to the entire liability of the taxpayer or other person against whom the administrative action was taken by the Department of Taxation and Finance, including taxes, interest, additions to the tax and penalties, with respect to which the offer in compromise is filed, and all questions of such liability are conclusively settled thereby. Neither the taxpayer nor the Department of Taxation and Finance shall, upon acceptance of an offer in compromise, be permitted to reopen the case for any reason, except upon a showing of fraud, malfeasance or misrepresentation of a material fact. Acceptance of an offer in compromise will not be a ground for compromise regarding other years or periods.

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