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 the American Association of Attorney-CPAs.

An obscure provision in the act will require partial payments of 20 percent with the submission of offers. Although Congress scores this as a revenue raiser, the proposal will lead to fewer offers being submitted, and, for offers that are submitted, lead to lower amounts being submitted, said E. Martin Davidoff, chairman of the association's IRS Tax Liaison Committee.

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