The passage of H.R. 3, the Safe, Accountable, Flexible and Efficient Transportation Act of 2005, will effectively destroy the Internal Revenue Service's offer-in-compromise program, according to both the American Association of Attorney-CPAs and the American Institute of CPAs.

A provision in the act would require partial payments of 20 percent with the submission of offers. Although Congress considers this a revenue-raiser, the proposal will lead to fewer offers being submitted, and, for offers that are submitted, to lower amounts being submitted, said E. Martin Davidoff, chair of the IRS Tax Liaison Committee of the AAA-CPA.

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