{"meta":{"key":"d014--main","task":"D014","title":"Tax Debt Resolution and Cancellation Taxation","parent_title":"Tax debt resolution and cancellation taxation","edition":"initial","path":"/research/d014--main/","kind":"initial","category":"subject","role":"foundation","area_numbers":[19,67],"groups":["debt-types","collections"],"date":"2026-10-22","tables":8,"claims":50,"sources":40,"review_status":"revise","review_complete":true,"sha256":"da1f6d6c31437b778181f77201ecc3965d3ae1510caa0e273990331d2504b810","headings":["Research baseline, scope, and status","A019 — Tax debt resolution","Federal assessment, liens, levies, and collection sequence","Installment agreements and ordinary payment alternatives","Offers in compromise","Hardship and levy release","Penalties and interest","Payroll tax and responsible-person exposure","Bankruptcy as an alternative","California income, sales/use, payroll and local taxes","A019 practical decision rule","A067 — Taxes after cancellation","General COD rule and why Form 1099-C is not the tax rule","Exceptions before exclusions","Bankruptcy exclusion","Insolvency exclusion","Ordering and tax attributes","Qualified principal residence debt after the 2025 expiration","Student loans and the 2026 transition","Farm debt and real-property business debt","Partnerships, S corporations and debt restructurings","Joint debt and spouses","Foreclosure and repossession","\\text{amount realized on property}","\\text{cancelled recourse balance}","California treatment after cancellation","Credit reporting, collateral, guarantors and validity","Worked examples, comparisons, and publication opportunities","Source register","Material claim register, coverage, and researcher self-check"],"generation_provenance":{"actual_route":null,"actual_model":null,"actual_mode":null,"provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"D014/initial","facets":{"geography":["us","us-ca"],"debt_type":["tax"],"stage":[],"subject":["tax-cancellation"]},"scope":"","pending_corrections":0},"markdown":"# D014 — Tax Debt Resolution and Cancellation Taxation\n\n## Research baseline, scope, and status\n\n**Assignment:** SettleADebt.com shared research library D014\n\n**Assigned areas:** A019 Tax debt; A067 Taxes after cancellation\n\n**Baseline and actual research check date:** **October 22, 2026, America/Los_Angeles**\n\n**Use:** Reusable public research, not advice concerning any particular taxpayer, borrower, business, or transaction.\n\nThis report treats federal tax law as the nationwide core, then separately addresses California and Orange County/City of Orange as concrete state/local exemplars. A fifty-state plus every-county/municipality survey was not possible from the assigned scope and should **not** be inferred from the California examples. Tribal tax collection and tribal cancellation-tax rules were not tied to a specified tribe or tax and remain outside the verified findings. Federal tax statutes consulted were current House U.S. Code text available in October 2026; the current §108 page includes 2025 amendments and the principal-residence transition through January 1, 2026. 1\n\nThe controlling hierarchy used here is: statutes and regulations for legal rules; Supreme Court decisions for adjudicated federal procedural rules; IRS/Treasury and state/local tax-agency materials for administrative policy and current programs. No private-creditor contract proposition is made in A019 because federal, state and local tax liabilities arise primarily under statute and agency programs rather than consumer-credit agreements. Accordingly, no private “complete creditor agreement” was applicable. IRS payment agreements and offers in compromise are governmental collection arrangements, not private retail-credit contracts. 2\n\nSeveral **2026 transition issues are unusually important**:\n\n| Issue | Status at Oct. 22, 2026 | Research consequence |\n| --- | --- | --- |\n| Federal qualified-principal-residence COD exclusion | The permanent-looking text does **not** provide an unrestricted 2026 exclusion. §108(a)(1)(E) applies to a discharge before Jan. 1, 2026, or a later discharge under an arrangement entered into and evidenced in writing before Jan. 1, 2026. [D014-C038] 3 | Do not publish “mortgage forgiveness is tax-free” for a new 2026 workout. |\n| Broad 2021–2025 student-loan COD exclusion | Expired/replaced. Current §108(f)(5) concerns death/disability; separate service-program exclusions remain. [D014-C039] 3 | A 2026 student-loan discharge cannot be assumed federally excluded merely because similar 2021–2025 discharges were. |\n| IRS installment-plan terminology | IRS changed its administrative program effective May 31, 2026: “Simple Payment Plans” replaced older streamlined rules for specified balances. [D014-C008] 4 | Older IRS pages discussing a fixed 72-month streamlined rule can be stale. |\n| Form 982 guidance | IRS’s Form 982 landing page was updated Aug. 27, 2026, but the separate detailed instructions surfaced in research remain an older revision. [D014-C037] 5 | For 2026 transition rules, statute and current IRS topic/publication material outrank stale form instructions. |\n| California 2026 COD return mechanics | Latest final California return instructions reviewed were for 2025. They show significant federal nonconformity, including principal-residence COD after 2017. [D014-C045] 6 | Hold exact 2026 California line-number instructions until final 2026 forms/guidance are verified. |\n\nA key editorial principle follows from this research: **“Debt settled for less” and “tax debt settled for less” are not interchangeable tax propositions.** General COD rules clearly cover cancellation of indebtedness, and IRS internal guidance says discharged debt owed to the federal government can be COD, but this research did **not** locate a controlling source establishing a universal rule that the unpaid portion of an accepted IRS offer in compromise itself produces Form 1099-C income to the taxpayer. That specific proposition is therefore a **publication hold**, not something to infer from ordinary credit-card settlements. [D014-C048] 7\n\n## A019 — Tax debt resolution\n\nTax debt resolution is not one program. The correct path depends first on **what tax is owed, who owes it, whether the assessment is correct, what collection power the taxing authority has, and whether the taxpayer seeks to dispute liability or merely obtain collection relief**.\n\n### Federal assessment, liens, levies, and collection sequence\n\n**D014-C001 — Statutory federal tax lien.** Under 26 U.S.C. §6321, when a person liable for tax neglects or refuses to pay after demand, a federal tax lien arises for the amount of tax plus interest, additions to tax, assessable penalties and collection costs, and reaches “all property and rights to property” belonging to the taxpayer. Filing a Notice of Federal Tax Lien, or NFTL, is therefore not the event that creates the underlying statutory lien; it is a public filing with important notice and priority consequences. 8\n\nThat distinction matters operationally. “Lien release,” “lien withdrawal,” “property discharge” and “subordination” should never be treated as synonyms:\n\n**D014-C013.** A **release** addresses the lien; a **discharge** removes specified property from the lien; **subordination** generally leaves the lien in place but permits another creditor to take priority; and **withdrawal** addresses the filed NFTL rather than erasing the underlying tax liability by itself. IRS materials expressly say that subordination does not remove the lien and that a certificate of discharge concerns particular property. 9\n\n**D014-C002 — NFTL hearing period.** Section 6320 requires notice of an NFTL filing generally within five business days, together with the right to request a collection due process hearing. IRS CDP guidance identifies a 30-day request period associated with Letter 3172. 10\n\n**D014-C003 — Levy notice.** A levy is the actual seizure/attachment collection device, distinct from the lien. Section 6330 generally requires written notice and an opportunity for a CDP hearing at least 30 days before the first levy covered by the statute. 11\n\nAt CDP, a taxpayer may raise collection alternatives and, in specified circumstances, underlying-liability issues; the statutory opportunity to dispute the liability matters, so CDP is not a universal second audit. The hearing officer also reviews statutory/procedural requirements and balances collection needs against intrusiveness under §6330. 11\n\n**D014-C004 — Tax Court review and Boechler.** Section 6330(d)(1) supplies a 30-day period to petition the Tax Court after a CDP determination. In *Boechler, P.C. v. Commissioner*, the Supreme Court held that this deadline is nonjurisdictional and subject to equitable tolling. That does **not** mean late petitions are routinely accepted; equitable tolling must be established on the facts, so the safe publication rule remains “file within the statutory 30 days.” 12\n\n**D014-C005 — Collection limitations period.** Section 6502 generally provides a **10-year collection period after assessment**, but that is only a starting rule. Statutory suspensions and extensions can change the actual Collection Statute Expiration Date, so “ten years and the tax disappears” is unsafe guidance. Bankruptcy, CDP and offer-in-compromise activity are among events that can interact with limitations periods. 13\n\n### Installment agreements and ordinary payment alternatives\n\n**D014-C006 — Installment-agreement authority.** Section 6159 authorizes the IRS to enter an installment agreement when doing so will facilitate collection. The statute also contains a much narrower guaranteed-installment provision for qualifying individual income-tax liabilities of no more than **$10,000 excluding penalties and interest**, subject to additional filing/payment history, financial-inability, future-compliance and full-payment-within-three-years conditions. This statutory $10,000 guarantee should not be confused with larger administratively available IRS plans. 14\n\nThe IRS can terminate an installment agreement for reasons including materially inaccurate information, jeopardized collection, significant changed financial condition, payment default, new tax noncompliance, or failure to provide requested financial information. Section 6159 generally contains pretermination protections, with exceptions such as jeopardy situations. 14\n\n**D014-C007 — Partial-payment installment agreements.** Section 6159 requires the IRS to review partial-payment installment agreements at least every two years. They are therefore not necessarily a fixed permanent resolution based on the taxpayer’s original financial condition. 14\n\n**D014-C008 — 2026 Simple Payment Plans.** IRS guidance effective in 2026 states that individuals with up to **$50,000** of assessed tax, penalties and interest can fall within current Simple Payment Plan criteria, with separate business thresholds: generally up to **$25,000** for certain in-business trust-fund tax balances and up to **$50,000** in specified other business/out-of-business circumstances. The corresponding Internal Revenue Manual update says these rules took effect May 31, 2026 and replaced older “streamlined” terminology and its prior fixed 72-month framework; the plan instead must fit within the available collection period. 4\n\nThat is an **administrative eligibility shortcut**, not a promise that every debtor under $50,000 receives the same payment, term, lien treatment or result.\n\n### Offers in compromise\n\n**D014-C009 — Legal grounds.** Section 7122 and Treas. Reg. §301.7122-1 recognize three central grounds:\n\n| Ground | Operative concept |\n| --- | --- |\n| Doubt as to liability | Genuine dispute over existence or amount of the legally correct liability. |\n| Doubt as to collectibility | Assets and income indicate the full liability cannot reasonably be collected. |\n| Effective tax administration | Liability may be legally correct and collectible, but exceptional circumstances, including economic hardship or qualifying public-policy/equity circumstances, justify compromise. |\n\n2\n\nThis distinction prevents a common sales error: **OIC is not simply “IRS debt settlement.”** A taxpayer contesting whether the tax is correct is in a different legal posture from a taxpayer admitting the assessment but unable to pay.\n\n**D014-C010 — Application economics.** Current IRS OIC guidance states a **$205 application fee** ordinarily applies. Under a lump-sum cash offer, the application ordinarily includes **20% of the offer amount**, with the balance payable in no more than five payments after acceptance. Periodic-payment offers follow different required-payment mechanics. Qualifying low-income individual applicants are exempt from the application fee and certain initial/ongoing offer payments while the offer is pending. 15\n\nThose payments are process requirements; they are **not** a formula proving that an offer will be accepted. The ultimate collectibility analysis involves assets, income, allowable expenses, future collection potential and applicable exceptions. No universal “pennies on the dollar” percentage is supported by the authorities reviewed.\n\nA rejected OIC generally has a **30-day administrative appeal window** under current IRS guidance. [D014-C020] 16\n\n### Hardship and levy release\n\n**D014-C011 — Currently not collectible.** IRS hardship guidance states that an account may be put into currently-not-collectible status when collection would cause financial hardship. CNC status **does not forgive the liability**; penalties and interest continue to accrue, and the IRS may request a Collection Information Statement such as Form 433-F, 433-A or 433-B and documentation of income, assets and expenses. 17\n\n**D014-C012 — Mandatory levy release.** Section 6343 requires release in several circumstances, including when the liability is satisfied or becomes legally unenforceable, when release facilitates collection, when an installment agreement requires release, and when the Secretary determines the levy is creating economic hardship because of the taxpayer’s financial condition. Other statutory release provisions address excessive levies and specified business property. 18\n\nThis makes a crucial distinction for content: **hardship can justify stopping a collection action without erasing the underlying tax debt.**\n\n### Penalties and interest\n\nThe balance can grow independently of the original tax.\n\n**D014-C014 — Federal failure-to-pay penalty.** Current IRS guidance states the ordinary failure-to-pay rate is **0.5% of unpaid tax for each month or part of a month**, up to **25%**. For a qualifying individual who timely filed and is in an approved payment plan, the rate can be **0.25% per month** during the agreement. After certain levy-notice periods, the rate can increase to **1% per month**. 19\n\n**D014-C015 — Failure to file.** The usual failure-to-file penalty is **5% of unpaid tax per month or part of a month**, generally capped at **25%**. IRS 2026 guidance identifies a minimum penalty for a return more than 60 days late, for returns required to be filed in 2026, of the lesser of **$525 or 100% of the tax required to be shown**. Interactions with failure-to-pay penalties require a return-specific calculation. 20\n\n**D014-C016 — Federal employment-tax deposit penalty.** IRS guidance gives escalating deposit penalty rates of **2%** for deposits one to five days late, **5%** for six to 15 days, **10%** for more than 15 days, and potentially **15%** after the applicable notice-and-demand period. 21\n\n**D014-C017 — Interest.** The IRS underpayment rate for the fourth quarter of 2026 is **7% annually** for ordinary individual underpayments, with federal tax interest generally computed daily. Rates change by quarter, so a static 7% figure should never be carried into a future article without a current-rate check. 22\n\nPenalty relief is a separate issue from compromise. Current IRS reasonable-cause guidance says qualifying penalties may be removed or reduced where the taxpayer establishes reasonable cause and good faith based on the facts; that does not itself eliminate the underlying tax or statutory interest. 23\n\n### Payroll tax and responsible-person exposure\n\nPayroll-tax debt is materially different from ordinary individual income-tax debt.\n\n**D014-C018 — Trust Fund Recovery Penalty.** IRS guidance under §6672 describes TFRP exposure for responsible persons who willfully fail to collect, account for or pay over trust-fund taxes. The amount generally consists of the unpaid employee trust-fund portion—such as withheld income tax and employee FICA—not the employer’s matching share. A proposed assessment is communicated through Letter 1153, with an administrative appeal period generally **60 days**, or **75 days** where the notice is addressed outside the United States. 24\n\n“Responsible person” is functional, not merely a job-title test; officers, partners, owners, employees, trustees or agents can qualify depending on authority and conduct. “Willfulness” does not necessarily require a bad motive; deliberately paying other creditors while knowing trust-fund taxes are due can satisfy the standard. 25\n\n**D014-C019.** More than one person can be assessed, but the IRS’s administrative guidance states that the trust-fund amount should be collected only once in total. A business OIC for employment-tax liability also does not necessarily eliminate separate §6672 exposure of responsible persons. 26\n\nFor a business owner, this is the tax equivalent of a “guarantor/secondary liability” issue and must be separately checked before describing settlement of the entity’s liability as resolving the owner’s exposure.\n\n### Bankruptcy as an alternative\n\nBankruptcy can be an alternative to administrative collection, but the shorthand “old tax debt is dischargeable after three years” is dangerously incomplete.\n\n**D014-C028.** IRS Publication 908 states that many tax debts are excepted from discharge and that the result depends on bankruptcy chapter, type of tax, return filing history, assessment timing and other facts. Bankruptcy priority rules include a **240-day assessment period** for certain income/gross-receipts taxes, with extensions for specified OIC and prior-stay periods. Valid pre-bankruptcy tax liens can also survive the elimination of personal liability and remain enforceable against encumbered property. 27\n\nThus a discharge analysis requires at least the tax type, return due date, actual filing date, assessment date, fraud/evasion status, prior bankruptcy dates, OIC dates and lien status. U.S. Courts likewise cautions that bankruptcy discharge has statutory exceptions, including certain taxes. 28\n\n### California income, sales/use, payroll and local taxes\n\nThe following California/Orange County treatment is a **jurisdiction-specific exemplar**, not a nationwide state-law rule.\n\n**California Franchise Tax Board — income/franchise tax.**\n\n**D014-C021.** FTB guidance gives taxpayers **60 days** to protest a Notice of Proposed Assessment under California Revenue and Taxation Code §19041; if no timely action is taken, the assessment can become final, while interest continues. 29\n\n**D014-C022.** FTB operates an offer-in-compromise program for taxpayers seeking settlement of a final, undisputed tax liability for less than the full amount, generally requiring required returns to be filed and the amount owed to be agreed before the collection OIC is pursued. FTB also has installment-agreement review procedures; its published guidance gives a 30-day review period following certain installment-agreement rejections. 30\n\nFTB’s Taxpayer Advocate can become relevant to immediate economic hardship involving wage garnishment, bank levy or tax-lien collection problems. 31\n\n**California Department of Tax and Fee Administration — sales/use and administered business taxes.**\n\n**D014-C023.** CDTFA distinguishes liens from levies, permits payment arrangements, and its collection publication describes a preliminary lien notice generally sent at least **30 days** before filing a lien. After demand and applicable process, CDTFA can use levies against property such as bank accounts, wages and accounts receivable. 32\n\nCDTFA has an OIC program. Its current policy says an offer will generally be evaluated against what it expects to collect over a reasonable period—described in its FAQ as **typically four years**, not as an entitlement or fixed statutory settlement formula. [D014-C024] 33\n\nCurrent CDTFA guidance also describes temporary authority for some **active businesses through January 1, 2028**, but only for “qualified” liabilities meeting statutory/program conditions; tax reimbursement actually collected from customers and not remitted is treated differently. 34\n\n**California Employment Development Department — payroll taxes.**\n\n**D014-C025.** EDD’s current employer portal permits payroll-tax account payments and adding a payment plan; EDD materials also identify the statewide multi-agency OIC process. For July through December 2026, EDD publishes a **7% annual interest rate** on delinquent payroll taxes. 35\n\nThis research verified the existence of EDD payment-plan/OIC pathways but did **not** fully reconstruct all EDD lien, levy, responsible-person and OIC eligibility rules from controlling California statutes. Those details remain a state-payroll publication hold.\n\n**Orange County secured property tax.**\n\n**D014-C026.** Orange County’s published standard calendar states that the first secured-property-tax installment is due November 1 and becomes delinquent after December 10 with a **10% penalty**; the second is due February 1 and becomes delinquent after April 10 with a **10% penalty plus a $23 collection charge**. Property that remains delinquent can enter tax-defaulted status; the county describes **1.5% per month** redemption penalties and five-year installment/redemption mechanisms. 36\n\nCalifornia’s property-tax enforcement structure can lead to power-to-sell status after the statutory delinquency period; Orange County explains the ordinary five-year framework and warns that once the property has reached the relevant power-to-sell stage, an installment plan may no longer be available. 37\n\nThis is not an OIC-style principal haircut. It is a statutory redemption/payment mechanism for property subject to a tax lien.\n\n**City of Orange business/TOT example.**\n\n**D014-C027.** City of Orange administrative guidance imposes delinquency penalties on late business-license obligations and separately describes delinquency penalties and interest for transient-occupancy tax. The precise local-tax penalty schedule is tax-specific; it should not be generalized to all Orange County cities or all municipal business taxes. 38\n\n### A019 practical decision rule\n\nThe most defensible workflow is:\n\n| Question | Primary path |\n| --- | --- |\n| Is the assessment legally wrong? | Protest/audit reconsideration/statutory appeal, doubt-as-to-liability OIC where applicable, or judicial route. |\n| Correct liability but affordable over time? | Full pay or installment agreement. |\n| Correct liability but full collection appears impossible? | Partial-pay IA or doubt-as-to-collectibility OIC, based on program facts. |\n| Collection would cause economic hardship? | CNC, levy release, ETA OIC, taxpayer-advocate channels as applicable. |\n| Payroll trust-fund tax involved? | Analyze entity liability and responsible-person/TFRP exposure separately. |\n| Secured tax lien affects property/refinance/sale? | Analyze release, discharge, subordination or withdrawal rather than assuming “settlement” is the only solution. |\n| Bankruptcy is being considered? | Perform tax-year-by-tax-year §523/§507 timing and lien analysis before filing. |\n\nNo verified source supports a universal settlement percentage, guaranteed approval timeline or credit-score improvement from any of these paths.\n\n## A067 — Taxes after cancellation\n\n### General COD rule and why Form 1099-C is not the tax rule\n\n**D014-C030 — General inclusion rule.** Section 61(a)(11) expressly includes “income from discharge of indebtedness” in gross income. Section 108 then supplies exceptions, exclusions and special rules. 39\n\nA basic consumer example is therefore:\n\n\nDebt immediately before settlement − amount legally remaining after cancellation = potential COD amount,\n\n\nbefore applying interest/deductibility rules, foreclosure mechanics, purchase-price rules, bankruptcy, insolvency or other exclusions.\n\n**D014-C031 — $600 is a reporting threshold, not a tax-free threshold.** Section 6050P generally requires specified applicable entities to report a qualifying cancellation of **$600 or more**, and debtor statements are generally due by January 31 following the calendar year. The Form 1099-C materials expressly warn that taxable cancellation can exist even below $600. 40\n\nTherefore:\n\n- $599 of taxable COD does not become tax-free because no Form 1099-C is required under §6050P.\n- A $20,000 Form 1099-C does not automatically mean $20,000 is taxable if an exception or exclusion applies.\n- Absence of Form 1099-C does not eliminate otherwise taxable COD.\n\n**D014-C032 — Reporting event versus taxability.** Treas. Reg. §1.6050P-1 uses “identifiable events” for information reporting, including bankruptcy, certain judicial relief, specified foreclosure events, probate, cancellation by agreement and a creditor decision/policy to discontinue collection. IRS Publication 4681 likewise warns that a taxpayer may have to report COD even without a 1099-C. The information return is evidence and a matching item; it is not itself the statute imposing the tax. 41\n\nThe recipient copy of Form 1099-C contains an especially important current instruction: where an identifiable event has occurred but the debt has not actually been discharged, income belongs in the year of **actual discharge**, absent another rule. [D014-C049] 42\n\nThat is why a disputed 1099-C should be reconciled to the settlement agreement, account ledger, court order, foreclosure documents and applicable law rather than blindly treated as conclusive.\n\n### Exceptions before exclusions\n\nIRS Topic 431 and Publication 4681 distinguish “exceptions” from §108 exclusions. Exceptions generally mean there is no COD income item to exclude; exclusions generally operate on what otherwise would be COD and may trigger tax-attribute consequences. 43\n\n**D014-C033.** Two statutory examples are especially important:\n\n1. Under §108(e)(2), COD income is not realized to the extent payment of the cancelled liability would itself have produced a deduction.\n2. Under §108(e)(5), a qualifying reduction of seller-financed purchase-money debt for a solvent purchaser outside bankruptcy is treated as a **purchase-price adjustment** rather than COD.\n\n3\n\nThis can matter for business debt because cancelled accrued deductible expenses or interest can receive treatment different from cancelled loan principal.\n\n### Bankruptcy exclusion\n\n**D014-C034.** Section 108(a)(1)(A) excludes COD where the discharge occurs in a Title 11 bankruptcy case. Section 108’s ordering rule gives the bankruptcy exclusion precedence over the insolvency, farm, qualified-real-property-business and principal-residence exclusions for a discharge occurring in the bankruptcy case. 3\n\nBankruptcy discharge of the underlying debt and tax treatment of the cancellation are related but separate questions. A debt can be discharged under the Bankruptcy Code while §108 controls whether resulting COD is included in gross income. IRS Publication 908 confirms that debt cancelled by reason of the bankruptcy discharge is not included on the debtor’s individual return, while tax-attribute rules can shift the economic consequence. 44\n\nFor individual chapter 7 or 11 cases where §1398 applies, §108(d)(8) can place tax-attribute reduction at the bankruptcy-estate level. 3\n\n### Insolvency exclusion\n\n**D014-C035.** Section 108(d)(3) defines insolvency as:\n\n**Liabilities immediately before discharge − fair market value of assets immediately before discharge**\n\nand §108(a)(3) limits the exclusion to the amount of insolvency. Thus:\n\n[\n\\text{Insolvency exclusion} =\n\\min(\\text{COD}, \\text{liabilities} - \\text{FMV of assets})\n]\n\nwhen liabilities exceed assets. 1\n\nTiming is critical: the balance sheet is measured **immediately before** the cancellation, not at year-end and not after the forgiven debt has vanished. IRS Publication 4681 provides an insolvency worksheet and instructs a taxpayer claiming this exclusion to use Form 982. 45\n\nInsolvency is therefore not synonymous with “could not afford the payment,” “negative monthly cash flow,” “had no cash,” or “settled because of hardship.”\n\n### Ordering and tax attributes\n\n**D014-C036.** Section 108 specifies ordering. Bankruptcy comes first for a bankruptcy-case discharge. Insolvency precedes the qualified farm and qualified real-property-business exclusions to the extent of insolvency. The qualified-principal-residence exclusion, where still available under its transition rule, takes precedence over insolvency unless the taxpayer elects insolvency instead. 3\n\n**D014-C037 — Attribute reduction.** For COD excluded under bankruptcy, insolvency and certain farm-debt rules, §108(b) can reduce tax attributes in this order:\n\n1. net operating loss;\n2. general business credit;\n3. minimum tax credit;\n4. capital-loss carryovers;\n5. property basis;\n6. passive-activity loss/credit carryovers;\n7. foreign-tax-credit carryovers.\n\nMost reductions are dollar-for-dollar, but specified credit carryovers are reduced **33⅓ cents for each $1 of excluded COD**. The statute also permits an election, within its limits, to reduce basis in depreciable property first. 46\n\nThus “excluded from current income” does **not** always mean “tax consequence disappears forever.” It can instead consume deductions, credits or basis that would have produced future tax benefits.\n\nForm 982 is the IRS form used to report qualifying §108 exclusions and corresponding attribute reductions. The IRS Form 982 landing page was current in August 2026, but detailed instructions located during the research were older; current statutory text should control any 2026 transition question. 5\n\n### Qualified principal residence debt after the 2025 expiration\n\n**D014-C038.** Current §108(a)(1)(E) is precise: qualified principal-residence indebtedness can qualify where it is discharged **before January 1, 2026**, or where the later discharge is **subject to an arrangement entered into and evidenced in writing before January 1, 2026**. 3\n\nSection 108(h) defines the relevant debt by reference to acquisition indebtedness and substitutes a federal limit of **$750,000**, or **$375,000 for married filing separately**. The exclusion also reduces basis in the principal residence, and it does not apply when forgiveness arises from services or another factor not directly connected to decline in residence value or the taxpayer’s financial condition. 3\n\nConsequently, a new mortgage modification signed in March 2026 cannot be advertised as qualifying merely because it concerns a principal residence. A pre-2026 written arrangement may preserve federal eligibility for a later discharge, but the documents must be examined.\n\n### Student loans and the 2026 transition\n\n**D014-C039.** Section 108’s amendment history shows that the broad special rule covering qualifying student-loan discharges during **2021 through 2025** was replaced in 2025. Current §108(f)(5) instead excludes qualifying student-loan discharges on account of death or total and permanent disability, subject to the statutory loan and Social Security number conditions. 3\n\nSeparate provisions remain for specified service-contingent student loan programs and for National Health Service Corps/state healthcare loan-repayment programs. 3\n\nTherefore, “student loan forgiveness is federally tax-free” is too broad for a 2026 article.\n\n### Farm debt and real-property business debt\n\nBusiness COD requires entity and debt-classification analysis.\n\n**D014-C050 — Qualified farm debt.** Section 108(g) generally requires the debt to have been incurred directly in the farming trade/business, with **50% or more of aggregate gross receipts for the three preceding tax years** attributable to farming, and discharge by a qualified person. The exclusion is limited by tax attributes and basis in qualified property and follows the bankruptcy/insolvency ordering rules. 3\n\n**D014-C051 — Qualified real-property business debt.** Section 108(a)(1)(D) is unavailable to C corporations. Section 108(c) requires qualifying debt connected with and secured by real property used in a trade/business and imposes debt-over-value and depreciable-real-property-basis limits; the exclusion generally reduces basis in depreciable real property. 3\n\nNeither provision supports calling ordinary business credit-card forgiveness tax-free.\n\n### Partnerships, S corporations and debt restructurings\n\n**D014-C041.** Under §108(d)(6), partnership §108 exclusions and attribute consequences are generally applied **at the partner level**. Under §108(d)(7), they are generally applied **at the S-corporation level**. Current Form 1065 instructions likewise state that partnership COD is separately stated and that the extent of §108 exclusion is usually determined by each partner. 47\n\nThat difference can make the same partnership cancellation taxable to one partner and excluded for another, depending on each partner’s insolvency or other §108 status.\n\n**D014-C042.** A business restructuring need not involve cash to create COD. Under §108(e)(8), when a debtor corporation transfers stock or a debtor partnership transfers an equity interest to satisfy debt, the debt is treated as satisfied for the **fair market value** of the equity. Under §108(e)(10), replacement debt can be treated as satisfying old debt for the new instrument’s statutory **issue price**. A significant discount can therefore produce COD in an exchange that a business might colloquially describe as a “refinance.” 3\n\n### Joint debt and spouses\n\n**D014-C040.** IRS Publication 4681 addresses joint and several debt directly. Two debtors can each receive a Form 1099-C showing the **full cancelled balance**, yet neither necessarily reports the full amount. Relevant facts include state law, which person received the proceeds, allocation of interest deductions, allocation of basis in jointly owned property and availability of COD exceptions/exclusions. 48\n\nThe IRS example allocates joint debt between spouses according to the economic use of loan proceeds and then performs separate insolvency calculations for separate returns. 48\n\nTherefore, “divide a joint 1099-C fifty-fifty” is not a universal rule.\n\n### Foreclosure and repossession\n\nA foreclosure or repossession can create **two separate tax computations**: disposition gain/loss and COD.\n\n**D014-C043 — Recourse debt.** When a taxpayer is personally liable, the transferred property is treated as disposed of. IRS Publication 4681 describes the amount realized using the property’s FMV under the relevant foreclosure computation, while debt forgiven above the property value can generate separate ordinary COD income. The character of disposition gain/loss depends on the property. 49\n\nConceptually:\n\n# [\n\\text{Disposition gain/loss}\n\n## \\text{amount realized on property}\n\n\\text{adjusted basis}\n]\n\nand, where the creditor actually cancels the recourse deficiency,\n\n# [\n\\text{potential COD}\n\n## \\text{cancelled recourse balance}\n\n\\text{amount attributable to the property}\n]\n\nsubject to the precise foreclosure facts and §108.\n\n**D014-C044 — Nonrecourse debt.** For property securing nonrecourse debt, Treas. Reg. §1.1001-2 includes discharged liabilities in amount realized. IRS guidance explains that foreclosure generally does **not** create a separate COD item; the entire nonrecourse debt is taken into the disposition amount realized. 50\n\nThat difference can radically change both the amount and character of income. A secured-debt settlement article therefore must identify recourse status before calculating “forgiven debt.”\n\n### California treatment after cancellation\n\n**D014-C045.** California FTB guidance says cancelled or forgiven debt is generally income, but California does not simply copy every current federal §108 exclusion. Most importantly for housing, the final 2025 Schedule CA instructions state that California **does not conform to the federal principal-residence COD exclusion for dispositions occurring after December 31, 2017** and requires a California adjustment where federal income was excluded. 51\n\nThe FTB mortgage-forgiveness page, last updated December 17, 2025, directs affected taxpayers to include the federal return and federal Form 982 with the California return and states there is no comparable California Form 982. [D014-C046] 52\n\nThis creates a classic state-federal mismatch:\n\n\n**Federal exclusion ≠ automatic California exclusion.**\n\n\nAs of the October 22, 2026 research baseline, final California **2026** Schedule CA instructions were not verified in this research. The 2025 nonconformity is therefore strong evidence of the existing state position but exact 2026 return-line instructions remain a publication hold pending final 2026 materials.\n\n### Credit reporting, collateral, guarantors and validity\n\nNo researched primary source supports a universal claim that debt settlement, an OIC, CNC status, Form 1099-C receipt, a tax lien or cancellation of debt will change a consumer’s credit score by a particular number or for a particular period. **All specific credit-score claims are held.**\n\nCollateral can materially change both collection and tax consequences: a federal lien can attach to property rights; a valid pre-bankruptcy lien can survive personal discharge against property; and foreclosure/repo creates sale/disposition calculations distinct from COD. 8\n\nGuarantor and secondary-liability analysis is likewise fact-specific. This report verified federal TFRP exposure and joint-debtor COD rules, but did not establish a universal federal COD rule for every private business guarantor who pays, is released, or remains contingently liable. That topic should not be extrapolated from the spouse/joint-debt example.\n\n## Worked examples, comparisons, and publication opportunities\n\n**Example — Insolvency exclusion with partial taxable COD.**\n\nAssume:\n\n- personal unsecured balance immediately before settlement: $80,000;\n- settlement payment: $30,000;\n- creditor legally cancels the remaining $50,000;\n- liabilities immediately before cancellation, including the debt: $300,000;\n- FMV of all relevant assets immediately before cancellation: $270,000;\n- no bankruptcy or other higher-priority rule applies.\n\nPotential COD:\n\n[\n$80,000-$30,000=$50,000\n]\n\nInsolvency:\n\n[\n$300,000-$270,000=$30,000\n]\n\nExcludable under insolvency:\n\n[\n\\min($50,000,$30,000)=$30,000\n]\n\nPotentially taxable COD:\n\n[\n$50,000-$30,000=\\boxed{$20,000}\n]\n\nForm 982 would be used for the insolvency exclusion, and tax-attribute reduction must then be considered. [D014-C035, C037] 53\n\n**Limitation:** this example assumes the $50,000 is actual COD principal and does not resolve interest, deductible business debt, joint liability, state tax, property security or other exclusions.\n\n**Example — Why being “underwater” is not enough.**\n\nAssume a consumer owes $40,000 on unsecured debt and owns only $5,000 of cash, but also owns retirement/investment/property interests with $100,000 FMV and has $70,000 of total liabilities immediately before cancellation.\n\n[\n$70,000\\text{ liabilities}-$105,000\\text{ assets}=-$35,000\n]\n\nOn these simplified inputs the taxpayer is **not insolvent**, even though liquid cash is only $5,000. The statutory test is liabilities versus FMV of assets, not ability to make the next payment. [D014-C035] 1\n\n**Example — Tax-attribute cost of excluded COD.**\n\nAssume $20,000 of COD is excluded under insolvency and the taxpayer has:\n\n- $12,000 NOL subject to reduction;\n- sufficient general-business-credit carryover for the remaining reduction;\n- no election to reduce depreciable-property basis first.\n\nFirst:\n\n[\n$20,000-$12,000 = $8,000\n]\n\nThe NOL is reduced by $12,000.\n\nFor the remaining $8,000 of excluded COD, a qualifying credit carryover reduction is:\n\n[\n$8,000\\times33\\tfrac13% = $2,666.67\n]\n\nsubject to the taxpayer actually possessing that credit attribute and the complete statutory ordering rules. [D014-C037] 3\n\nThis demonstrates why “no tax because insolvent” can still have future tax cost.\n\n**Example — Recourse foreclosure.**\n\nAssume:\n\n- recourse mortgage balance: $250,000;\n- property FMV at transfer: $200,000;\n- adjusted tax basis: $180,000;\n- lender takes the property and cancels the entire $50,000 deficiency;\n- ignore selling expenses and special home-loss rules.\n\nDisposition component:\n\n[\n$200,000-$180,000=\\boxed{$20,000\\text{ gain}}\n]\n\nCOD component:\n\n[\n$250,000-$200,000=\\boxed{$50,000\\text{ potential COD}}\n]\n\nThe $50,000 is then tested separately against bankruptcy, insolvency and other exclusions. [D014-C043] 49\n\n**Example — Same property, nonrecourse loan.**\n\nUse the same $250,000 balance, $200,000 FMV and $180,000 basis, but make the debt nonrecourse.\n\nGenerally:\n\n[\n\\text{amount realized}=$250,000\n]\n\n[\n$250,000-$180,000=\\boxed{$70,000\\text{ disposition gain}}\n]\n\nThere is generally **no separate $50,000 COD item** from the foreclosure. [D014-C044] 50\n\nThe recourse classification changed a “$20,000 gain + $50,000 COD” structure into a “$70,000 disposition gain” structure before other tax provisions are applied.\n\n**Example — Joint debt where both people receive a full 1099-C.**\n\nAssume:\n\n- $40,000 actually cancelled;\n- both debtors were jointly and severally liable;\n- facts support a 60%/40% economic allocation;\n- Debtor A therefore bears $24,000 and Debtor B $16,000;\n- A is insolvent by $10,000 immediately before cancellation;\n- B is insolvent by $30,000.\n\nA:\n\n[\n$24,000-$10,000=\\boxed{$14,000\\text{ potentially taxable COD}}\n]\n\nB:\n\n[\n\\min($16,000,$30,000)=$16,000\\text{ excluded}\n]\n\nEven if **each** receives a 1099-C stating $40,000, the IRS’s own guidance says facts and circumstances determine each person’s reportable share. [D014-C040] 48\n\n**Example — OIC application cash is not a settlement formula.**\n\nAssume an individual proposes a qualifying lump-sum OIC of $15,000 and does not qualify for the low-income exception.\n\nApplication fee:\n\n[\n$205\n]\n\nInitial 20% payment:\n\n[\n$15,000\\times20%=$3,000\n]\n\nInitial cash submitted:\n\n[\n$3,000+$205=\\boxed{$3,205}\n]\n\nThat does **not** establish that $15,000 is an acceptable offer. It only illustrates current payment mechanics. [D014-C010] 15\n\n**Example — Three months of failure-to-pay penalty versus approved-plan rate.**\n\nAssume $20,000 of unpaid individual income tax, timely return, and for illustration three full months with no changing principal.\n\nOrdinary 0.5% monthly rate:\n\n[\n$20,000\\times0.005\\times3=\\boxed{$300}\n]\n\nQualifying 0.25% approved-installment rate:\n\n[\n$20,000\\times0.0025\\times3=\\boxed{$150}\n]\n\nInterest would accrue separately and actual IRS computations account for exact dates, changing balances and interactions. [D014-C014, C017] 19\n\n**Resolution comparison.**\n\n| Tool | Changes legal amount owed? | Typical purpose | Key failure case | Collection / collateral point | COD-tax research point |\n| --- | --- | --- | --- | --- | --- |\n| Liability protest / DTL | Potentially | Tax is wrong | Missed procedural opportunity, insufficient substantive basis | Can determine correct assessment | Reduction because tax was never legally owed is conceptually different from forgiving a valid private debt; exact tax-compromise COD issue held where necessary. |\n| Full-pay IA | No | Time to pay | Default/new noncompliance | Lien can still matter | No COD merely from paying over time. |\n| Partial-pay IA | Not immediately | Pay less over remaining collection period when appropriate | Financial review; changed circumstances | Reviewed at least every two years [C007] | No publication claim that eventual CSED balance automatically generates COD. |\n| OIC | Yes, if accepted and completed | DTL, collectibility, ETA | Eligibility/valuation/compliance failure | Program settlement of tax liability | **Taxability of the compromised federal-tax remainder not verified as a universal COD rule; hold.** |\n| CNC | No | Hardship | IRS later determines ability to pay | Collection paused, lien/debt can remain | No cancellation merely from CNC. |\n| Bankruptcy | Potentially discharges personal liability | Broader insolvency proceeding | Nondischargeable taxes, timing, liens | Valid liens can survive against property | COD discharged in Title 11 generally excluded under §108. |\n| Lien discharge/subordination | No | Deal with specific collateral/priority | Does not eliminate underlying debt | Property-specific | Not a debt cancellation by itself. |\n\n**Draft article/tool/document opportunities.**\n\nA **Tax Debt Resolution Decision Tree** is strongly supported: “Is liability correct?” → “tax type?” → “collection stage?” → IA/OIC/CNC/lien remedy/bankruptcy analysis. It should explicitly branch trust-fund payroll tax away from ordinary income-tax debt.\n\nA **COD Insolvency Calculator** can implement:\n\n[\n\\text{insolvency}=\\max(0,\\text{liabilities}-\\text{FMV assets})\n]\n\n[\n\\text{excluded COD}=\\min(\\text{COD},\\text{insolvency})\n]\n\nbut must display a warning that asset/liability classification, timing, entity type and other exclusions require tax review.\n\nA **Foreclosure COD Split Calculator** should force the user to choose recourse versus nonrecourse before displaying results. It should separately output disposition amount realized, adjusted basis, gain/loss and potential COD.\n\nA **2026 COD Transition Checklist** should ask: date of cancellation; written mortgage workout date; type of student-loan discharge; bankruptcy status; insolvency immediately before discharge; entity type; state; and whether collateral was surrendered.\n\nA **1099-C Reconciliation Worksheet** should compare creditor, debt ID, box 2 principal/interest, cancellation date/identifiable-event code, actual settlement documents, joint-debtor allocation, exclusion relied upon and Form 982 position. IRS itself distinguishes identifiable-event reporting from actual taxability. 41\n\n**Open questions and publication holds.**\n\n| Topic | Why held | Next evidence needed |\n| --- | --- | --- |\n| Tax treatment of the unpaid portion of an accepted IRS OIC | No directly controlling authority located establishing a universal COD/1099-C result for compromised federal tax liabilities. | Treasury regulation, published revenue ruling, Chief Counsel authority or current explicit IRS OIC tax guidance. |\n| 2026 California COD line mechanics | Latest final Schedule CA reviewed was 2025. | Final 2026 Schedule CA/Form 540 instructions and any 2026 statutory conformity legislation. |\n| All-state/local tax settlement rules | No state can stand in for another. | Jurisdiction-by-jurisdiction statutes and agency manuals. |\n| California EDD responsible-person/OIC details | Existence of plans/OIC verified; complete statutory mechanics not. | Current California Unemployment Insurance Code and EDD collection manual/forms. |\n| Private business guarantor COD allocation | Joint-debtor and partnership rules do not resolve every guaranty fact pattern. | Controlling federal cases/regulations specific to guarantor release/payment/subrogation. |\n| Credit-score impact | No primary authority supports a universal score effect. | Current CRA/FICO/VantageScore treatment for the exact tradeline/public record; avoid generic claims meanwhile. |\n| 2026 Form 982 detailed instructions | Current landing page exists but surfaced detailed instructions lag statutory amendments. | Final IRS 2026 Form 982 and instructions. |\n| Tribal tax debt | Tribe not specified. | Relevant tribal code, court and collection authority for identified jurisdiction. |\n\n## Source register\n\nAll source checks below are **October 22, 2026** unless a narrower publication/update date is stated. “Read” means the supporting passage was actually fetched and examined during this research; “PDF screenshot” identifies visual inspection rather than reliance solely on a search extract. Sources identified only incidentally and not relied upon for a material claim are not presented as verified authority.\n\n| Source ID | Source, issuer, direct URL | Pinpoint / version / status | Scope, access method, limits |\n| --- | --- | --- | --- |\n| **D014-S001** | **26 U.S.C. §108, Income from discharge of indebtedness**, U.S. House Office of Law Revision Counsel. `https://uscode.house.gov/us/usc/119-118/t26/s108/` 1 | §§108(a), (b), (c), (d), (e), (f), (g), (h); current snapshot includes 2025 amendment notes and Jan. 1, 2026 QPRI transition. | Federal; HTML opened/read by pinpoint. Primary controlling statute. |\n| **D014-S002** | **26 U.S.C. §61**, U.S. House OLRC. `https://uscode.house.gov/` — §61(a)(11). 39 | Gross income includes discharge-of-indebtedness income. | Federal; primary statute, fetched/read. |\n| **D014-S003** | **26 U.S.C. §6050P**, U.S. House OLRC. `https://uscode.house.gov/` — §6050P. 40 | $600 information-reporting rule; debtor statements. Current through Oct. 2026 code update identified in source. | Federal; primary statute. Reporting, not substantive income exclusion. |\n| **D014-S004** | **26 C.F.R. §1.6050P-1**, Treasury/IRS, eCFR. `https://www.ecfr.gov/current/title-26/section-1.6050P-1` 41 | Identifiable events for Form 1099-C. | Federal; current regulation; HTML fetched/read. |\n| **D014-S005** | **Publication 4681 (2025), Canceled Debts, Foreclosures, Repossessions, and Abandonments**, IRS. `https://www.irs.gov/publications/p4681` 45 | Insolvency; joint debt; recourse/nonrecourse; 1099-C; 2025 tax year. | Federal administrative guidance; HTML opened/searched by passage. Latest final annual Pub. 4681 located, but 2025 tax year rather than final 2026 edition. |\n| **D014-S006** | **About Form 1099-C**, IRS. `https://www.irs.gov/forms-pubs/about-form-1099-c` 54 | Updated Mar. 30, 2026; $600 filing trigger. | Federal, current agency page. |\n| **D014-S007** | **Form 1099-C / Instructions for Forms 1099-A and 1099-C**, IRS. `https://www.irs.gov/pub/irs-pdf/f1099c.pdf` and `https://www.irs.gov/pub/irs-pdf/i1099ac.pdf` 42 | Rev. Apr. 2025; recipient instructions include actual-discharge timing warning. | Federal; PDF text fetched. Form version remains operative material located in 2026 but revision is Apr. 2025. |\n| **D014-S008** | **About Form 982**, IRS. `https://www.irs.gov/forms-pubs/about-form-982` 5 | Updated Aug. 27, 2026. | Federal; current landing page. Detailed separate instructions located were older, a noted limit. |\n| **D014-S009** | **26 C.F.R. §1.1001-2, Discharge of liabilities**, Treasury/eCFR. `https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR36dbe7d18edf3fe` 50 | §1.1001-2(a), amount realized includes liabilities from which transferor is discharged. | Federal; controlling regulation; HTML read. |\n| **D014-S010** | **26 C.F.R. §§1.108-7 and 1.1017-1**, Treasury/eCFR. `https://www.ecfr.gov/current/title-26/` 55 | Attribute and basis reductions. | Federal; current regulations fetched/read. |\n| **D014-S011** | **26 U.S.C. §6321**, U.S. House OLRC. `https://uscode.house.gov/` — §6321. 8 | Statutory lien after demand; tax, interest, additions, penalties, costs; all property/rights. | Federal; controlling statute. |\n| **D014-S012** | **26 U.S.C. §6320**, U.S. House OLRC. `https://uscode.house.gov/` — §6320. 10 | NFTL notice/CDP process; five-business-day statutory notice framework. | Federal; controlling statute. |\n| **D014-S013** | **26 U.S.C. §6330**, U.S. House OLRC. `https://uscode.house.gov/` — §6330. 11 | Pre-levy CDP; 30-day notice; Tax Court review. | Federal; controlling statute. |\n| **D014-S014** | **26 U.S.C. §6343**, U.S. House OLRC. `https://uscode.house.gov/` — §6343. 18 | Mandatory levy release conditions and hardship. | Federal; controlling statute. |\n| **D014-S015** | **26 U.S.C. §6159**, U.S. House OLRC. `https://uscode.house.gov/` — §6159. 14 | Installment agreements; guaranteed $10,000 provision; termination; PPIA review. | Federal; controlling statute. |\n| **D014-S016** | **26 U.S.C. §6502**, U.S. House OLRC. `https://uscode.house.gov/` — §6502. 13 | General 10-year collection period after assessment. | Federal; statute. Actual CSED requires suspension/extension analysis. |\n| **D014-S017** | **26 U.S.C. §7122 / Treas. Reg. §301.7122-1**, Congress/Treasury. `https://uscode.house.gov/` and `https://www.ecfr.gov/current/title-26/section-301.7122-1` 2 | Compromise authority; doubt as to liability, collectibility, effective tax administration. | Federal primary statute/regulation. |\n| **D014-S018** | **Simple Payment Plans**, IRS. `https://www.irs.gov/payments/simple-payment-plans-for-individuals-and-businesses` 4 | Current 2026 administrative balance thresholds. | Federal agency program; policy can change without statute. |\n| **D014-S019** | **IRM Simple Payment Plan update**, IRS. `https://www.irs.gov/irm/` 56 | IRM updated July 23, 2026; May 31, 2026 effective change replacing streamlined framework. | Federal internal administrative guidance; not statute. |\n| **D014-S020** | **Offer in Compromise**, IRS. `https://www.irs.gov/payments/offer-in-compromise` 15 | $205 fee; 20% lump-sum initial payment; payment alternatives/low-income exception. | Federal current program guidance. |\n| **D014-S021** | **Currently-not-collectible / temporary collection delay**, IRS. `https://www.irs.gov/businesses/small-businesses-self-employed/temporarily-delay-the-collection-process` 17 | Current July 2026-era page; hardship, no forgiveness, continuing P&I. | Federal agency guidance. |\n| **D014-S022** | **Failure-to-pay / failure-to-file / deposit-penalty guidance**, IRS. `https://www.irs.gov/payments/failure-to-pay-penalty` and related IRS penalty pages. 19 | Current 2026 rates cited in report. | Federal agency guidance; exact calculation remains return/account specific. |\n| **D014-S023** | **Federal tax interest rate Q4 2026 / Rev. Rul. 2026-15**, IRS. 57 | Q4 2026 underpayment rate 7% for ordinary individual underpayments. | Federal; quarter-specific. Must refresh each quarter. |\n| **D014-S024** | **Trust Fund Recovery Penalty guidance**, IRS. `https://www.irs.gov/businesses/small-businesses-self-employed/trust-fund-recovery-penalty` 24 | §6672 responsible/willful standards; trust-fund amount; Letter 1153 appeal period. | Federal administrative guidance interpreting statute; entity/person-specific analysis needed. |\n| **D014-S025** | **Collection Due Process FAQs / Form 12153 guidance**, IRS. `https://www.irs.gov/appeals/collection-due-process-cdp-faqs` 58 | 30-day CDP periods; equivalent-hearing consequences. | Federal administrative procedure. |\n| **D014-S026** | ***Boechler, P.C. v. Commissioner*, No. 20-1472**, U.S. Supreme Court, Apr. 21, 2022. `https://www.supremecourt.gov/opinions/21pdf/20-1472_6j37.pdf` 12 | Slip op. syllabus and pp. 2–11; §6330(d)(1) deadline nonjurisdictional and equitably tollable. | Federal controlling case; **PDF screenshot/read**, not discovery-only. |\n| **D014-S027** | **Publication 908 (2025), Bankruptcy Tax Guide**, IRS. `https://www.irs.gov/publications/p908` 27 | Tax dischargeability, liens, §507 timing, COD in bankruptcy. | Federal agency guidance; bankruptcy outcomes require Bankruptcy Code analysis and individual dates. |\n| **D014-S028** | **Chapter 7 / Chapter 13 Bankruptcy Basics**, U.S. Courts. `https://www.uscourts.gov/court-programs/bankruptcy/bankruptcy-basics/chapter-7-bankruptcy-basics` 28 | Discharge and statutory exceptions including certain taxes. | Federal judiciary educational material; not substitute for Code/case-specific analysis. |\n| **D014-S029** | **FTB Offer in Compromise**, California Franchise Tax Board. `https://www.ftb.ca.gov/pay/if-you-cant-pay/offer-in-compromise.html` 30 | Final/undisputed liability, filing/compliance prerequisites. | California income/franchise tax administrative program. |\n| **D014-S030** | **FTB NPA/protest guidance**, California Franchise Tax Board. 29 | 60-day NPA protest; installment-agreement rejection review. | California; agency guidance referencing R&TC §§19041–19042. |\n| **D014-S031** | **CDTFA Offer in Compromise / Collection Procedures**, California Department of Tax and Fee Administration. `https://www.cdtfa.ca.gov/taxes-and-fees/offer-in-compromise.htm` 33 | OIC; typical four-year collectibility policy; active-business rule through Jan. 1, 2028; liens/levies. | California sales/use and CDTFA-administered taxes. Four-year statement is agency policy, not universal statutory settlement period. |\n| **D014-S032** | **EDD Payroll Taxes / e-Services for Business**, California EDD. `https://edd.ca.gov/en/payroll_taxes/` and `https://edd.ca.gov/en/payroll_taxes/e-Services_for_Business/` 59 | Payment-plan access; Multi-Agency OIC form listing. | California payroll tax; collection-law detail only partially researched. |\n| **D014-S033** | **EDD payroll-tax interest rate**, California EDD. 60 | July–Dec. 2026: 7%. | California payroll tax; period-specific. |\n| **D014-S034** | **Orange County Property Tax Important Dates / Five-Year Payment Plan**, Orange County Treasurer-Tax Collector. 36 | Nov. 1/Dec. 10; Feb. 1/Apr. 10; penalties; default/redemption and power-to-sell framework. | Orange County, California; property tax only. Actual tax bill/calendar and statutory exceptions control. |\n| **D014-S035** | **City of Orange business-license and transient-occupancy-tax guidance**, City of Orange. 38 | Local delinquency penalties/interest. | City of Orange only; not countywide or statewide. |\n| **D014-S036** | **FTB 1099 guidance for recipients**, California Franchise Tax Board. `https://www.ftb.ca.gov/file/personal/income-types/information-returns-1099.html` 51 | Updated June 10, 2026; cancelled debt generally income. | California individual tax guidance. |\n| **D014-S037** | **2025 Schedule CA (540) Instructions**, California FTB. `https://www.ftb.ca.gov/forms/2025/2025-540-ca-instructions.html` 6 | Principal-residence COD federal nonconformity after Dec. 31, 2017. | Final 2025 state-return instructions. Exact 2026 line mechanics remain unverified. |\n| **D014-S038** | **Mortgage forgiveness debt relief**, California FTB. `https://www.ftb.ca.gov/file/personal/income-types/mortgage-forgiveness-debt-relief.html` 52 | Updated Dec. 17, 2025; federal Form 982 copy; no similar CA form. | California; applicability depends on tax year/facts. |\n| **D014-S039** | **2025 Instructions for Form 1065**, IRS. `https://www.irs.gov/instructions/i1065` 61 | Partnership COD separately stated; partner §108 treatment. | Federal administrative return guidance; complements §108(d)(6). |\n| **D014-S040** | **Reasonable-cause penalty relief**, IRS. `https://www.irs.gov/payments/penalty-relief-for-reasonable-cause` 23 | Updated June 21, 2026. | Federal administrative penalty relief; fact-specific. |\n\n**Discovery/unresolved-source note:** searches located current Form 656/656-B listings, IRS internal manuals discussing OIC, and current California EDD multi-agency OIC materials, but those were not used to manufacture unverified OIC acceptance formulas or EDD collection rules. The research also searched specifically for official authority on whether the compromised remainder of an IRS tax liability creates COD/1099-C income; no sufficiently direct controlling authority was located. 62\n\n## Material claim register, coverage, and researcher self-check\n\n**Material claim register**\n\n| Claim ID | Area | Precise claim | Primary/source support and pinpoint | Conditions / evidence limits |\n| --- | --- | --- | --- | --- |\n| **D014-C001** | A019 | Federal tax lien reaches all taxpayer property/rights after liability, demand and neglect/refusal; amount includes tax and statutory additions. | D014-S011, 26 U.S.C. §6321. 8 | Priority against third parties has additional rules not fully covered here. |\n| **D014-C002** | A019 | NFTL notice generally within five business days; CDP request has statutory 30-day framework. | D014-S012, §6320; IRS CDP guidance. 10 | Notice dates must be read from actual notice. |\n| **D014-C003** | A019 | Levy generally requires at least 30-day pre-levy CDP notice. | D014-S013, §6330. 11 | Statutory exceptions exist; not a universal bar to every collection measure. |\n| **D014-C004** | A019 | CDP Tax Court petition period is 30 days; *Boechler* makes it nonjurisdictional and equitably tollable. | D014-S013/S026. 12 | Equitable tolling is not automatic. |\n| **D014-C005** | A019 | General federal collection period is 10 years after assessment, subject to suspensions/extensions. | D014-S016. 13 | Never calculate CSED from assessment + 10 years without event history. |\n| **D014-C006** | A019 | §6159 authorizes IAs; statutory guaranteed IA uses ≤$10,000 tax-liability threshold and three-year full-pay condition plus other requirements. | D014-S015, §6159. 14 | Different from administrative Simple Payment Plan thresholds. |\n| **D014-C007** | A019 | PPIAs reviewed at least every two years. | D014-S015, §6159. 14 | Financial changes may matter. |\n| **D014-C008** | A019 | 2026 Simple Plan criteria include $50k individual threshold and specified business thresholds; program changed effective May 31, 2026. | D014-S018/S019. 4 | Administrative program; can change. |\n| **D014-C009** | A019 | OIC grounds include doubt as to liability, doubt as to collectibility and effective tax administration. | D014-S017, §7122 / Reg. §301.7122-1. 2 | Not every hardship qualifies for compromise. |\n| **D014-C010** | A019 | OIC fee $205; lump offer ordinarily requires 20%; low-income exception exists. | D014-S020. 15 | Current program mechanics; not acceptance formula. |\n| **D014-C011** | A019 | CNC can pause collection for hardship but does not forgive debt; P&I continue. | D014-S021. 17 | IRS can reassess ability to pay. |\n| **D014-C012** | A019 | §6343 requires levy release for specified conditions, including economic hardship. | D014-S014. 18 | Does not itself erase tax. |\n| **D014-C013** | A019 | Release, property discharge, subordination and NFTL withdrawal are legally distinct. | IRS lien guidance. 9 | Exact eligibility differs by remedy. |\n| **D014-C014** | A019 | FTP penalty ordinarily 0.5%/month, max 25%; qualifying approved-plan rate 0.25%; specified post-notice rate can reach 1%. | D014-S022. 19 | Exact monthly interaction depends on account. |\n| **D014-C015** | A019 | FTF penalty ordinarily 5%/month, max 25%; >60-day minimum for returns required in 2026 is lesser of $525 or 100% tax. | D014-S022. 20 | Tax-year-specific minimum changes over time. |\n| **D014-C016** | A019 | Federal tax-deposit penalty tiers 2%/5%/10%/15%. | D014-S022. 21 | Deposit timing/notice controls tier. |\n| **D014-C017** | A019 | Q4 2026 ordinary federal underpayment interest rate is 7% annually. | D014-S023. 57 | Quarter-specific; must refresh. |\n| **D014-C018** | A019 | TFRP reaches unpaid trust-fund portion; responsible/willful test; Letter 1153 appeal generally 60/75 days. | D014-S024. 24 | Person-specific factual inquiry. |\n| **D014-C019** | A019 | Multiple responsible persons may be assessed but trust-fund amount is collected only once; entity compromise may not end responsible-person exposure. | IRS IRM. 26 | Administrative guidance. |\n| **D014-C020** | A019 | Rejected OIC generally carries 30-day administrative appeal period. | IRS Appeals guidance. 16 | Actual rejection letter controls. |\n| **D014-C021** | A019 | California FTB NPA protest period is 60 days. | D014-S030 / R&TC §19041 agency guidance. 29 | Other CA appeal stages not exhaustively mapped. |\n| **D014-C022** | A019 | FTB OIC applies to qualifying final/undisputed liabilities after required returns and collection alternatives are addressed. | D014-S029. 30 | California only. |\n| **D014-C023** | A019 | CDTFA uses liens/levies and OIC; preliminary lien notice generally ≥30 days under current collection guidance. | D014-S031. 32 | Tax/program-specific. |\n| **D014-C024** | A019 | CDTFA FAQ describes reasonable collection period as typically four years in OIC evaluation. | D014-S031. 34 | Agency policy, not settlement guarantee. |\n| **D014-C025** | A019 | EDD provides account payment plans/OIC pathways; Jul.–Dec. 2026 interest 7%. | D014-S032/S033. 35 | Detailed EDD statutory collection rules partial. |\n| **D014-C026** | A019 | Orange secured property tax standard calendar uses 10% late penalties; second installment adds $23; redemption framework includes 1.5% monthly and five-year mechanisms. | D014-S034. 36 | Actual bill and deadline exceptions control. |\n| **D014-C027** | A019 | City of Orange has separate business-license/TOT delinquency charges. | D014-S035. 38 | City-specific only. |\n| **D014-C028** | A019/A067 | Some tax debt can be discharged in bankruptcy, many taxes are excepted, and valid liens can survive against property. | D014-S027/S028. 27 | Requires tax-year/date-specific §523/§507 analysis. |\n| **D014-C030** | A067 | COD is included in federal gross income absent exception/exclusion. | D014-S002/S001, §§61(a)(11), 108. 39 | Amount/timing can be complex. |\n| **D014-C031** | A067 | $600 is Form 1099-C reporting threshold, not federal taxable-income threshold. | D014-S003/S006/S007. 40 | Applicable-entity/identifiable-event rules also required. |\n| **D014-C032** | A067 | 1099-C identifiable event does not itself resolve substantive taxability; no form does not eliminate taxable COD. | D014-S004/S005. 41 | Actual cancellation and §108 still control. |\n| **D014-C033** | A067 | Deductible-debt and qualifying purchase-money reduction rules can prevent COD treatment. | D014-S001, §108(e)(2),(5). 3 | Purchase-price rule has statutory conditions. |\n| **D014-C034** | A067 | COD discharged in Title 11 case can be excluded under §108(a)(1)(A). | D014-S001/S027. 63 | Discharge must fall within statutory bankruptcy rule. |\n| **D014-C035** | A067 | Insolvency = liabilities − FMV assets immediately before discharge; exclusion limited to insolvency amount. | D014-S001/S005. 1 | Asset/liability identification can be contested. |\n| **D014-C036** | A067 | §108 specifies priority among bankruptcy, insolvency, farm/QRPBI and QPRI exclusions. | D014-S001 §108(a)(2). 3 | Election can alter QPRI/insolvency ordering. |\n| **D014-C037** | A067 | Excluded COD can reduce NOLs, credits, capital losses, basis, passive attributes, foreign credits; specified credit reductions are 33⅓ cents/$1. | D014-S001/S010. 3 | Depends on exclusion and available attributes. |\n| **D014-C038** | A067 | QPRI exclusion is limited to pre-2026 discharge or pre-2026 written arrangement; debt cap $750k/$375k MFS. | D014-S001 §108(a)(1)(E),(h). 3 | Federal only; California does not mirror current federal rule. |\n| **D014-C039** | A067 | Broad 2021–2025 student-loan exclusion ended; current §108(f)(5) concerns death/disability, while service-program exclusions remain. | D014-S001 §108(f). 3 | Type of discharge matters. |\n| **D014-C040** | A067 | Joint debt is not automatically allocated by the full amount on each 1099-C or 50/50; facts and state law matter. | D014-S005. 48 | Joint return issues beyond IRS example not exhaustively analyzed. |\n| **D014-C041** | A067 | Partnership §108 analysis is generally partner-level; S-corporation analysis generally corporate-level. | D014-S001 §108(d)(6),(7); S039. 47 | Other entity/classification rules can affect result. |\n| **D014-C042** | A067 | Debt-for-equity uses FMV; debt-for-debt can use issue price, creating potential COD. | D014-S001 §108(e)(8),(10). 3 | Detailed issue-price regulations may be needed in actual transaction. |\n| **D014-C043** | A067 | Recourse foreclosure can create separate disposition gain/loss and COD. | D014-S005, Pub. 4681 / Pub. 544. 49 | Deficiency retained versus cancelled changes amount. |\n| **D014-C044** | A067 | Nonrecourse foreclosure generally puts full debt in amount realized and does not create separate COD. | D014-S009/S005. 50 | Character of disposition gain/loss still must be analyzed. |\n| **D014-C045** | A067 | California generally recognizes cancelled debt income and, in final 2025 instructions, does not conform to federal principal-residence COD exclusion after 2017. | D014-S036/S037. 51 | Exact final 2026 CA return mechanics not verified. |\n| **D014-C046** | A067 | FTB mortgage guidance calls for federal Form 982 copy and says California has no similar Form 982. | D014-S038. 52 | Tax-year/fact applicability must be checked. |\n| **D014-C047** | A067 | Bankruptcy COD exclusion can transfer attribute-reduction consequences to bankruptcy estate in specified individual Ch. 7/11 cases. | §108(d)(8); Pub. 908. 63 | §1398 conditions apply. |\n| **D014-C048** | A019/A067 | No universal verified rule was found that an accepted IRS OIC necessarily creates taxable COD or Form 1099-C on compromised tax balance. | Targeted IRS searches; general government-debt COD materials did not squarely resolve OIC tax-liability compromise. 7 | **Unresolved/publication hold; do not infer either taxability or nontaxability.** |\n| **D014-C049** | A067 | Form 1099-C instructions say if an identifiable event occurs but debt is not actually discharged, income generally belongs in year of actual discharge. | D014-S007 recipient instructions. 42 | Other timing doctrines can require professional analysis. |\n| **D014-C050** | A067 | Qualified farm debt requires direct farming connection, 50% three-year gross-receipts test and qualified creditor, subject to limits. | D014-S001 §108(g). 3 | Specialized business exclusion. |\n| **D014-C051** | A067 | QRPBI exclusion is unavailable to C corporations and is limited by property/debt/basis conditions. | D014-S001 §108(a)(1)(D),(c). 3 | Election and basis reduction apply. |\n\n**Coverage table**\n\n| Assigned area / subtopic | Status | Findings / claims | Missing evidence or next action |\n| --- | --- | --- | --- |\n| A019 — Federal income-tax debt | **Answered** | C001–C017, C020, C028 | Account-specific assessment/notice chronology always required. |\n| A019 — State income tax | **Answered for California; partial nationwide** | C021–C022 | Build separate modules for every other state. |\n| A019 — Local income tax | **Partial** | Local-tax principle addressed; Orange has no general local personal income tax module developed here. | Research each locality that imposes local income tax. |\n| A019 — Federal payroll tax | **Answered materially** | C016, C018–C019 | Detailed §6672 litigation defenses can be expanded. |\n| A019 — California payroll tax | **Partial** | C025 | Open controlling EDD/UIC collection and responsible-person provisions. |\n| A019 — Sales/use tax | **Answered for California; partial nationwide** | C023–C024 | Other states have different responsible-person, trust-tax and OIC rules. |\n| A019 — Property tax | **Answered for Orange County exemplar; partial nationwide** | C026 | Each county/state foreclosure/redemption system differs. |\n| A019 — Business/local tax | **Partial** | C022–C025, C027 | No nationwide municipal-tax matrix. |\n| A019 — Penalties | **Answered federally; selected CA/local** | C014–C017, C026–C027 | Exact state/local penalties require jurisdictional modules. |\n| A019 — Interest | **Answered for federal Q4 2026; CA EDD current period** | C017, C025 | Rates are time-sensitive and require refresh. |\n| A019 — Assessments/debt validity | **Answered federally; CA FTB core** | C009, C021 | Full audit/reconsideration and every state appeal route not mapped. |\n| A019 — Liens | **Answered federally; CA sales/property substantially addressed** | C001–C002, C013, C023, C026 | EDD and other-state lien statutes partial. |\n| A019 — Levies | **Answered federally; CA CDTFA substantially addressed** | C003, C012, C023 | Exemption schedules and wrongful-levy litigation not comprehensively catalogued. |\n| A019 — Agreements/installments | **Answered federally; CA examples** | C006–C008, C022, C025–C026 | Other states/localities unresolved. |\n| A019 — Offer in compromise | **Answered federal; CA FTB/CDTFA material** | C009–C010, C020, C022–C024 | EDD complete OIC eligibility partial. |\n| A019 — Hardship | **Answered federal; CA advocate path noted** | C011–C012 | State-specific hardship standards need separate modules. |\n| A019 — Appeals/litigation | **Answered federal CDP/OIC core** | C002–C004, C020–C021 | Full deficiency litigation, refund suits and all state appellate routes outside this module. |\n| A019 — Bankruptcy alternative | **Answered at issue-spotting level** | C028 | Tax-year-specific discharge calculator would require fuller §507/§523 matrix. |\n| A019 — Credit consequences | **Unresolved intentionally** | Publication hold | No support for universal credit-score effect; research exact CRA/scoring proposition before publishing one. |\n| A019 — Tribal law | **Unresolved/not jurisdictionally assigned** | Scope note | Need identified tribe and governing tax code. |\n| A067 — General COD income | **Answered** | C030–C033 | Transaction-specific timing may require case law. |\n| A067 — 1099-C | **Answered materially** | C031–C032, C049 | Complete issuer correction procedure could be separately expanded. |\n| A067 — Form 982 | **Answered materially** | C035–C037, C046 | Final detailed 2026 federal instructions not verified. |\n| A067 — Insolvency | **Answered** | C035 | Complex contingent liabilities/assets may require case law. |\n| A067 — Bankruptcy exclusion | **Answered** | C034, C047 | Individual bankruptcy facts remain case-specific. |\n| A067 — Tax attributes | **Answered** | C037, C047 | Specialized attribute/basis elections can be expanded. |\n| A067 — Principal-residence debt | **Answered federally; CA mismatch addressed** | C038, C045–C046 | 2026 final CA instructions pending verification. |\n| A067 — Farm debt | **Answered** | C050 | Specialized agricultural entities may need additional rules. |\n| A067 — Real-property business debt | **Answered materially** | C051 | Detailed basis-election mechanics can be expanded. |\n| A067 — Student loans/current-year transition | **Answered federally** | C039 | State treatment must be checked separately. |\n| A067 — Joint debt | **Answered materially** | C040 | Community-property/joint-return permutations deserve state-specific expansion. |\n| A067 — Partnership/S corporation/business debt | **Answered materially** | C041–C042, C050–C051 | C-corp, guarantor, related-party and complex debt-modification rules can be deeper standalone modules. |\n| A067 — Foreclosure/repo | **Answered materially** | C043–C044 | Property character, §121, depreciation recapture and state law remain separate layers. |\n| A067 — Federal tax-debt compromise itself | **Unresolved** | C048 | Need direct published authority before saying accepted IRS OIC remainder is or is not COD. |\n| A067 — State cancellation taxation | **Answered for California 2025 final guidance; partial for 2026/all states** | C045–C046 | Refresh California when final 2026 instructions issue; state-by-state conformity survey required. |\n| A067 — Credit consequences | **Unresolved intentionally** | Publication hold | Form 1099-C tax reporting does not establish universal credit-reporting outcome. |\n\n**Researcher self-check.** The research verified the current federal statutory COD structure in §§61 and 108; the §6050P/Form 1099-C distinction; insolvency formula and timing; bankruptcy, farm, QRPBI and principal-residence exclusions; the 2026 principal-residence and student-loan transitions; tax-attribute reduction order and credit-reduction rate; partnership/S-corporation placement of §108 analysis; debt-for-equity/debt rules; recourse/nonrecourse foreclosure treatment; core federal tax-lien, levy, CDP, installment, OIC and hardship statutes/programs; *Boechler* from the Supreme Court’s actual opinion; current 2026 Simple Payment Plan changes; OIC fees/payment mechanics; major federal late-payment/filing/deposit penalties and Q4 2026 interest; federal TFRP basics; California FTB/CDTFA/EDD resolution programs to the levels stated; Orange County secured-property-tax collection mechanics; and California’s latest final COD/mortgage-conformity guidance. 64\n\nThe research **did not verify** a universal COD consequence from settlement of an IRS tax liability itself; a fifty-state/local-tax survey; complete California EDD responsible-person/collection law; tribe-specific law; universal private-guarantor COD rules; any universal settlement percentage or approval time; any universal credit-score consequence; or final 2026 California return-line instructions. Those matters remain explicitly unresolved rather than inferred. No borrower data, private accounts or nonpublic tax records were accessed, no creditor or government agency was contacted, and no claim is made that any file was saved to the shared research library.\n\n","tables":[{"headers":["Issue","Status at Oct. 22, 2026","Research consequence"],"index":0,"links":[],"rows":[["Issue","Status at Oct. 22, 2026","Research consequence"],["Federal qualified-principal-residence COD exclusion","The permanent-looking text does not provide an unrestricted 2026 exclusion. §108(a)(1)(E) applies to a discharge before Jan. 1, 2026, or a later discharge under an arrangement entered into and evidenced in writing before Jan. 1, 2026. [D014-C038] \n3","Do not publish “mortgage forgiveness is tax-free” for a new 2026 workout."],["Broad 2021–2025 student-loan COD exclusion","Expired/replaced. Current §108(f)(5) concerns death/disability; separate service-program exclusions remain. [D014-C039] \n3","A 2026 student-loan discharge cannot be assumed federally excluded merely because similar 2021–2025 discharges were."],["IRS installment-plan terminology","IRS changed its administrative program effective May 31, 2026: “Simple Payment Plans” replaced older streamlined rules for specified balances. [D014-C008] \n4","Older IRS pages discussing a fixed 72-month streamlined rule can be stale."],["Form 982 guidance","IRS’s Form 982 landing page was updated Aug. 27, 2026, but the separate detailed instructions surfaced in research remain an older revision. [D014-C037] \n5","For 2026 transition rules, statute and current IRS topic/publication material outrank stale form instructions."],["California 2026 COD return mechanics","Latest final California return instructions reviewed were for 2025. They show significant federal nonconformity, including principal-residence COD after 2017. [D014-C045] \n6","Hold exact 2026 California line-number instructions until final 2026 forms/guidance are verified."]]},{"headers":["Ground","Operative concept"],"index":1,"links":[],"rows":[["Ground","Operative concept"],["Doubt as to liability","Genuine dispute over existence or amount of the legally correct liability."],["Doubt as to collectibility","Assets and income indicate the full liability cannot reasonably be collected."],["Effective tax administration","Liability may be legally correct and collectible, but exceptional circumstances, including economic hardship or qualifying public-policy/equity circumstances, justify compromise."]]},{"headers":["Question","Primary path"],"index":2,"links":[],"rows":[["Question","Primary path"],["Is the assessment legally wrong?","Protest/audit reconsideration/statutory appeal, doubt-as-to-liability OIC where applicable, or judicial route."],["Correct liability but affordable over time?","Full pay or installment agreement."],["Correct liability but full collection appears impossible?","Partial-pay IA or doubt-as-to-collectibility OIC, based on program facts."],["Collection would cause economic hardship?","CNC, levy release, ETA OIC, taxpayer-advocate channels as applicable."],["Payroll trust-fund tax involved?","Analyze entity liability and responsible-person/TFRP exposure separately."],["Secured tax lien affects property/refinance/sale?","Analyze release, discharge, subordination or withdrawal rather than assuming “settlement” is the only solution."],["Bankruptcy is being considered?","Perform tax-year-by-tax-year §523/§507 timing and lien analysis before filing."]]},{"headers":["Tool","Changes legal amount owed?","Typical purpose","Key failure case","Collection / collateral point","COD-tax research point"],"index":3,"links":[],"rows":[["Tool","Changes legal amount owed?","Typical purpose","Key failure case","Collection / collateral point","COD-tax research point"],["Liability protest / DTL","Potentially","Tax is wrong","Missed procedural opportunity, insufficient substantive basis","Can determine correct assessment","Reduction because tax was never legally owed is conceptually different from forgiving a valid private debt; exact tax-compromise COD issue held where necessary."],["Full-pay IA","No","Time to pay","Default/new noncompliance","Lien can still matter","No COD merely from paying over time."],["Partial-pay IA","Not immediately","Pay less over remaining collection period when appropriate","Financial review; changed circumstances","Reviewed at least every two years [C007]","No publication claim that eventual CSED balance automatically generates COD."],["OIC","Yes, if accepted and completed","DTL, collectibility, ETA","Eligibility/valuation/compliance failure","Program settlement of tax liability","Taxability of the compromised federal-tax remainder not verified as a universal COD rule; hold."],["CNC","No","Hardship","IRS later determines ability to pay","Collection paused, lien/debt can remain","No cancellation merely from CNC."],["Bankruptcy","Potentially discharges personal liability","Broader insolvency proceeding","Nondischargeable taxes, timing, liens","Valid liens can survive against property","COD discharged in Title 11 generally excluded under §108."],["Lien discharge/subordination","No","Deal with specific collateral/priority","Does not eliminate underlying debt","Property-specific","Not a debt cancellation by itself."]]},{"headers":["Topic","Why held","Next evidence needed"],"index":4,"links":[],"rows":[["Topic","Why held","Next evidence needed"],["Tax treatment of the unpaid portion of an accepted IRS OIC","No directly controlling authority located establishing a universal COD/1099-C result for compromised federal tax liabilities.","Treasury regulation, published revenue ruling, Chief Counsel authority or current explicit IRS OIC tax guidance."],["2026 California COD line mechanics","Latest final Schedule CA reviewed was 2025.","Final 2026 Schedule CA/Form 540 instructions and any 2026 statutory conformity legislation."],["All-state/local tax settlement rules","No state can stand in for another.","Jurisdiction-by-jurisdiction statutes and agency manuals."],["California EDD responsible-person/OIC details","Existence of plans/OIC verified; complete statutory mechanics not.","Current California Unemployment Insurance Code and EDD collection manual/forms."],["Private business guarantor COD allocation","Joint-debtor and partnership rules do not resolve every guaranty fact pattern.","Controlling federal cases/regulations specific to guarantor release/payment/subrogation."],["Credit-score impact","No primary authority supports a universal score effect.","Current CRA/FICO/VantageScore treatment for the exact tradeline/public record; avoid generic claims meanwhile."],["2026 Form 982 detailed instructions","Current landing page exists but surfaced detailed instructions lag statutory amendments.","Final IRS 2026 Form 982 and instructions."],["Tribal tax debt","Tribe not specified.","Relevant tribal code, court and collection authority for identified jurisdiction."]]},{"headers":["Source ID","Source, issuer, direct URL","Pinpoint / version / status","Scope, access method, limits"],"index":5,"links":[],"rows":[["Source ID","Source, issuer, direct URL","Pinpoint / version / status","Scope, access method, limits"],["D014-S001","26 U.S.C. §108, Income from discharge of indebtedness, U.S. House Office of Law Revision Counsel. https://uscode.house.gov/us/usc/119-118/t26/s108/ \n1","§§108(a), (b), (c), (d), (e), (f), (g), (h); current snapshot includes 2025 amendment notes and Jan. 1, 2026 QPRI transition.","Federal; HTML opened/read by pinpoint. Primary controlling statute."],["D014-S002","26 U.S.C. §61, U.S. House OLRC. https://uscode.house.gov/ — §61(a)(11). \n39","Gross income includes discharge-of-indebtedness income.","Federal; primary statute, fetched/read."],["D014-S003","26 U.S.C. §6050P, U.S. House OLRC. https://uscode.house.gov/ — §6050P. \n40","$600 information-reporting rule; debtor statements. Current through Oct. 2026 code update identified in source.","Federal; primary statute. Reporting, not substantive income exclusion."],["D014-S004","26 C.F.R. §1.6050P-1, Treasury/IRS, eCFR. https://www.ecfr.gov/current/title-26/section-1.6050P-1 \n41","Identifiable events for Form 1099-C.","Federal; current regulation; HTML fetched/read."],["D014-S005","Publication 4681 (2025), Canceled Debts, Foreclosures, Repossessions, and Abandonments, IRS. https://www.irs.gov/publications/p4681 \n45","Insolvency; joint debt; recourse/nonrecourse; 1099-C; 2025 tax year.","Federal administrative guidance; HTML opened/searched by passage. Latest final annual Pub. 4681 located, but 2025 tax year rather than final 2026 edition."],["D014-S006","About Form 1099-C, IRS. https://www.irs.gov/forms-pubs/about-form-1099-c \n54","Updated Mar. 30, 2026; $600 filing trigger.","Federal, current agency page."],["D014-S007","Form 1099-C / Instructions for Forms 1099-A and 1099-C, IRS. https://www.irs.gov/pub/irs-pdf/f1099c.pdf and https://www.irs.gov/pub/irs-pdf/i1099ac.pdf \n42","Rev. Apr. 2025; recipient instructions include actual-discharge timing warning.","Federal; PDF text fetched. Form version remains operative material located in 2026 but revision is Apr. 2025."],["D014-S008","About Form 982, IRS. https://www.irs.gov/forms-pubs/about-form-982 \n5","Updated Aug. 27, 2026.","Federal; current landing page. Detailed separate instructions located were older, a noted limit."],["D014-S009","26 C.F.R. §1.1001-2, Discharge of liabilities, Treasury/eCFR. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR36dbe7d18edf3fe \n50","§1.1001-2(a), amount realized includes liabilities from which transferor is discharged.","Federal; controlling regulation; HTML read."],["D014-S010","26 C.F.R. §§1.108-7 and 1.1017-1, Treasury/eCFR. https://www.ecfr.gov/current/title-26/ \n55","Attribute and basis reductions.","Federal; current regulations fetched/read."],["D014-S011","26 U.S.C. §6321, U.S. House OLRC. https://uscode.house.gov/ — §6321. \n8","Statutory lien after demand; tax, interest, additions, penalties, costs; all property/rights.","Federal; controlling statute."],["D014-S012","26 U.S.C. §6320, U.S. House OLRC. https://uscode.house.gov/ — §6320. \n10","NFTL notice/CDP process; five-business-day statutory notice framework.","Federal; controlling statute."],["D014-S013","26 U.S.C. §6330, U.S. House OLRC. https://uscode.house.gov/ — §6330. \n11","Pre-levy CDP; 30-day notice; Tax Court review.","Federal; controlling statute."],["D014-S014","26 U.S.C. §6343, U.S. House OLRC. https://uscode.house.gov/ — §6343. \n18","Mandatory levy release conditions and hardship.","Federal; controlling statute."],["D014-S015","26 U.S.C. §6159, U.S. House OLRC. https://uscode.house.gov/ — §6159. \n14","Installment agreements; guaranteed $10,000 provision; termination; PPIA review.","Federal; controlling statute."],["D014-S016","26 U.S.C. §6502, U.S. House OLRC. https://uscode.house.gov/ — §6502. \n13","General 10-year collection period after assessment.","Federal; statute. Actual CSED requires suspension/extension analysis."],["D014-S017","26 U.S.C. §7122 / Treas. Reg. §301.7122-1, Congress/Treasury. https://uscode.house.gov/ and https://www.ecfr.gov/current/title-26/section-301.7122-1 \n2","Compromise authority; doubt as to liability, collectibility, effective tax administration.","Federal primary statute/regulation."],["D014-S018","Simple Payment Plans, IRS. https://www.irs.gov/payments/simple-payment-plans-for-individuals-and-businesses \n4","Current 2026 administrative balance thresholds.","Federal agency program; policy can change without statute."],["D014-S019","IRM Simple Payment Plan update, IRS. https://www.irs.gov/irm/ \n56","IRM updated July 23, 2026; May 31, 2026 effective change replacing streamlined framework.","Federal internal administrative guidance; not statute."],["D014-S020","Offer in Compromise, IRS. https://www.irs.gov/payments/offer-in-compromise \n15","$205 fee; 20% lump-sum initial payment; payment alternatives/low-income exception.","Federal current program guidance."],["D014-S021","Currently-not-collectible / temporary collection delay, IRS. https://www.irs.gov/businesses/small-businesses-self-employed/temporarily-delay-the-collection-process \n17","Current July 2026-era page; hardship, no forgiveness, continuing P&I.","Federal agency guidance."],["D014-S022","Failure-to-pay / failure-to-file / deposit-penalty guidance, IRS. https://www.irs.gov/payments/failure-to-pay-penalty and related IRS penalty pages. \n19","Current 2026 rates cited in report.","Federal agency guidance; exact calculation remains return/account specific."],["D014-S023","Federal tax interest rate Q4 2026 / Rev. Rul. 2026-15, IRS. \n57","Q4 2026 underpayment rate 7% for ordinary individual underpayments.","Federal; quarter-specific. Must refresh each quarter."],["D014-S024","Trust Fund Recovery Penalty guidance, IRS. https://www.irs.gov/businesses/small-businesses-self-employed/trust-fund-recovery-penalty \n24","§6672 responsible/willful standards; trust-fund amount; Letter 1153 appeal period.","Federal administrative guidance interpreting statute; entity/person-specific analysis needed."],["D014-S025","Collection Due Process FAQs / Form 12153 guidance, IRS. https://www.irs.gov/appeals/collection-due-process-cdp-faqs \n58","30-day CDP periods; equivalent-hearing consequences.","Federal administrative procedure."],["D014-S026","Boechler, P.C. v. Commissioner, No. 20-1472, U.S. Supreme Court, Apr. 21, 2022. https://www.supremecourt.gov/opinions/21pdf/20-1472_6j37.pdf \n12","Slip op. syllabus and pp. 2–11; §6330(d)(1) deadline nonjurisdictional and equitably tollable.","Federal controlling case; PDF screenshot/read, not discovery-only."],["D014-S027","Publication 908 (2025), Bankruptcy Tax Guide, IRS. https://www.irs.gov/publications/p908 \n27","Tax dischargeability, liens, §507 timing, COD in bankruptcy.","Federal agency guidance; bankruptcy outcomes require Bankruptcy Code analysis and individual dates."],["D014-S028","Chapter 7 / Chapter 13 Bankruptcy Basics, U.S. Courts. https://www.uscourts.gov/court-programs/bankruptcy/bankruptcy-basics/chapter-7-bankruptcy-basics \n28","Discharge and statutory exceptions including certain taxes.","Federal judiciary educational material; not substitute for Code/case-specific analysis."],["D014-S029","FTB Offer in Compromise, California Franchise Tax Board. https://www.ftb.ca.gov/pay/if-you-cant-pay/offer-in-compromise.html \n30","Final/undisputed liability, filing/compliance prerequisites.","California income/franchise tax administrative program."],["D014-S030","FTB NPA/protest guidance, California Franchise Tax Board. \n29","60-day NPA protest; installment-agreement rejection review.","California; agency guidance referencing R&TC §§19041–19042."],["D014-S031","CDTFA Offer in Compromise / Collection Procedures, California Department of Tax and Fee Administration. https://www.cdtfa.ca.gov/taxes-and-fees/offer-in-compromise.htm \n33","OIC; typical four-year collectibility policy; active-business rule through Jan. 1, 2028; liens/levies.","California sales/use and CDTFA-administered taxes. Four-year statement is agency policy, not universal statutory settlement period."],["D014-S032","EDD Payroll Taxes / e-Services for Business, California EDD. https://edd.ca.gov/en/payroll_taxes/ and https://edd.ca.gov/en/payroll_taxes/e-Services_for_Business/ \n59","Payment-plan access; Multi-Agency OIC form listing.","California payroll tax; collection-law detail only partially researched."],["D014-S033","EDD payroll-tax interest rate, California EDD. \n60","July–Dec. 2026: 7%.","California payroll tax; period-specific."],["D014-S034","Orange County Property Tax Important Dates / Five-Year Payment Plan, Orange County Treasurer-Tax Collector. \n36","Nov. 1/Dec. 10; Feb. 1/Apr. 10; penalties; default/redemption and power-to-sell framework.","Orange County, California; property tax only. Actual tax bill/calendar and statutory exceptions control."],["D014-S035","City of Orange business-license and transient-occupancy-tax guidance, City of Orange. \n38","Local delinquency penalties/interest.","City of Orange only; not countywide or statewide."],["D014-S036","FTB 1099 guidance for recipients, California Franchise Tax Board. https://www.ftb.ca.gov/file/personal/income-types/information-returns-1099.html \n51","Updated June 10, 2026; cancelled debt generally income.","California individual tax guidance."],["D014-S037","2025 Schedule CA (540) Instructions, California FTB. https://www.ftb.ca.gov/forms/2025/2025-540-ca-instructions.html \n6","Principal-residence COD federal nonconformity after Dec. 31, 2017.","Final 2025 state-return instructions. Exact 2026 line mechanics remain unverified."],["D014-S038","Mortgage forgiveness debt relief, California FTB. https://www.ftb.ca.gov/file/personal/income-types/mortgage-forgiveness-debt-relief.html \n52","Updated Dec. 17, 2025; federal Form 982 copy; no similar CA form.","California; applicability depends on tax year/facts."],["D014-S039","2025 Instructions for Form 1065, IRS. https://www.irs.gov/instructions/i1065 \n61","Partnership COD separately stated; partner §108 treatment.","Federal administrative return guidance; complements §108(d)(6)."],["D014-S040","Reasonable-cause penalty relief, IRS. https://www.irs.gov/payments/penalty-relief-for-reasonable-cause \n23","Updated June 21, 2026.","Federal administrative penalty relief; fact-specific."]]},{"headers":["Claim ID","Area","Precise claim","Primary/source support and pinpoint","Conditions / evidence limits"],"index":6,"links":[],"rows":[["Claim ID","Area","Precise claim","Primary/source support and pinpoint","Conditions / evidence limits"],["D014-C001","A019","Federal tax lien reaches all taxpayer property/rights after liability, demand and neglect/refusal; amount includes tax and statutory additions.","D014-S011, 26 U.S.C. §6321. \n8","Priority against third parties has additional rules not fully covered here."],["D014-C002","A019","NFTL notice generally within five business days; CDP request has statutory 30-day framework.","D014-S012, §6320; IRS CDP guidance. \n10","Notice dates must be read from actual notice."],["D014-C003","A019","Levy generally requires at least 30-day pre-levy CDP notice.","D014-S013, §6330. \n11","Statutory exceptions exist; not a universal bar to every collection measure."],["D014-C004","A019","CDP Tax Court petition period is 30 days; Boechler makes it nonjurisdictional and equitably tollable.","D014-S013/S026. \n12","Equitable tolling is not automatic."],["D014-C005","A019","General federal collection period is 10 years after assessment, subject to suspensions/extensions.","D014-S016. \n13","Never calculate CSED from assessment + 10 years without event history."],["D014-C006","A019","§6159 authorizes IAs; statutory guaranteed IA uses ≤$10,000 tax-liability threshold and three-year full-pay condition plus other requirements.","D014-S015, §6159. \n14","Different from administrative Simple Payment Plan thresholds."],["D014-C007","A019","PPIAs reviewed at least every two years.","D014-S015, §6159. \n14","Financial changes may matter."],["D014-C008","A019","2026 Simple Plan criteria include $50k individual threshold and specified business thresholds; program changed effective May 31, 2026.","D014-S018/S019. \n4","Administrative program; can change."],["D014-C009","A019","OIC grounds include doubt as to liability, doubt as to collectibility and effective tax administration.","D014-S017, §7122 / Reg. §301.7122-1. \n2","Not every hardship qualifies for compromise."],["D014-C010","A019","OIC fee $205; lump offer ordinarily requires 20%; low-income exception exists.","D014-S020. \n15","Current program mechanics; not acceptance formula."],["D014-C011","A019","CNC can pause collection for hardship but does not forgive debt; P&I continue.","D014-S021. \n17","IRS can reassess ability to pay."],["D014-C012","A019","§6343 requires levy release for specified conditions, including economic hardship.","D014-S014. \n18","Does not itself erase tax."],["D014-C013","A019","Release, property discharge, subordination and NFTL withdrawal are legally distinct.","IRS lien guidance. \n9","Exact eligibility differs by remedy."],["D014-C014","A019","FTP penalty ordinarily 0.5%/month, max 25%; qualifying approved-plan rate 0.25%; specified post-notice rate can reach 1%.","D014-S022. \n19","Exact monthly interaction depends on account."],["D014-C015","A019","FTF penalty ordinarily 5%/month, max 25%; >60-day minimum for returns required in 2026 is lesser of $525 or 100% tax.","D014-S022. \n20","Tax-year-specific minimum changes over time."],["D014-C016","A019","Federal tax-deposit penalty tiers 2%/5%/10%/15%.","D014-S022. \n21","Deposit timing/notice controls tier."],["D014-C017","A019","Q4 2026 ordinary federal underpayment interest rate is 7% annually.","D014-S023. \n57","Quarter-specific; must refresh."],["D014-C018","A019","TFRP reaches unpaid trust-fund portion; responsible/willful test; Letter 1153 appeal generally 60/75 days.","D014-S024. \n24","Person-specific factual inquiry."],["D014-C019","A019","Multiple responsible persons may be assessed but trust-fund amount is collected only once; entity compromise may not end responsible-person exposure.","IRS IRM. \n26","Administrative guidance."],["D014-C020","A019","Rejected OIC generally carries 30-day administrative appeal period.","IRS Appeals guidance. \n16","Actual rejection letter controls."],["D014-C021","A019","California FTB NPA protest period is 60 days.","D014-S030 / R&TC §19041 agency guidance. \n29","Other CA appeal stages not exhaustively mapped."],["D014-C022","A019","FTB OIC applies to qualifying final/undisputed liabilities after required returns and collection alternatives are addressed.","D014-S029. \n30","California only."],["D014-C023","A019","CDTFA uses liens/levies and OIC; preliminary lien notice generally ≥30 days under current collection guidance.","D014-S031. \n32","Tax/program-specific."],["D014-C024","A019","CDTFA FAQ describes reasonable collection period as typically four years in OIC evaluation.","D014-S031. \n34","Agency policy, not settlement guarantee."],["D014-C025","A019","EDD provides account payment plans/OIC pathways; Jul.–Dec. 2026 interest 7%.","D014-S032/S033. \n35","Detailed EDD statutory collection rules partial."],["D014-C026","A019","Orange secured property tax standard calendar uses 10% late penalties; second installment adds $23; redemption framework includes 1.5% monthly and five-year mechanisms.","D014-S034. \n36","Actual bill and deadline exceptions control."],["D014-C027","A019","City of Orange has separate business-license/TOT delinquency charges.","D014-S035. \n38","City-specific only."],["D014-C028","A019/A067","Some tax debt can be discharged in bankruptcy, many taxes are excepted, and valid liens can survive against property.","D014-S027/S028. \n27","Requires tax-year/date-specific §523/§507 analysis."],["D014-C030","A067","COD is included in federal gross income absent exception/exclusion.","D014-S002/S001, §§61(a)(11), 108. \n39","Amount/timing can be complex."],["D014-C031","A067","$600 is Form 1099-C reporting threshold, not federal taxable-income threshold.","D014-S003/S006/S007. \n40","Applicable-entity/identifiable-event rules also required."],["D014-C032","A067","1099-C identifiable event does not itself resolve substantive taxability; no form does not eliminate taxable COD.","D014-S004/S005. \n41","Actual cancellation and §108 still control."],["D014-C033","A067","Deductible-debt and qualifying purchase-money reduction rules can prevent COD treatment.","D014-S001, §108(e)(2),(5). \n3","Purchase-price rule has statutory conditions."],["D014-C034","A067","COD discharged in Title 11 case can be excluded under §108(a)(1)(A).","D014-S001/S027. \n63","Discharge must fall within statutory bankruptcy rule."],["D014-C035","A067","Insolvency = liabilities − FMV assets immediately before discharge; exclusion limited to insolvency amount.","D014-S001/S005. \n1","Asset/liability identification can be contested."],["D014-C036","A067","§108 specifies priority among bankruptcy, insolvency, farm/QRPBI and QPRI exclusions.","D014-S001 §108(a)(2). \n3","Election can alter QPRI/insolvency ordering."],["D014-C037","A067","Excluded COD can reduce NOLs, credits, capital losses, basis, passive attributes, foreign credits; specified credit reductions are 33⅓ cents/$1.","D014-S001/S010. \n3","Depends on exclusion and available attributes."],["D014-C038","A067","QPRI exclusion is limited to pre-2026 discharge or pre-2026 written arrangement; debt cap $750k/$375k MFS.","D014-S001 §108(a)(1)(E),(h). \n3","Federal only; California does not mirror current federal rule."],["D014-C039","A067","Broad 2021–2025 student-loan exclusion ended; current §108(f)(5) concerns death/disability, while service-program exclusions remain.","D014-S001 §108(f). \n3","Type of discharge matters."],["D014-C040","A067","Joint debt is not automatically allocated by the full amount on each 1099-C or 50/50; facts and state law matter.","D014-S005. \n48","Joint return issues beyond IRS example not exhaustively analyzed."],["D014-C041","A067","Partnership §108 analysis is generally partner-level; S-corporation analysis generally corporate-level.","D014-S001 §108(d)(6),(7); S039. \n47","Other entity/classification rules can affect result."],["D014-C042","A067","Debt-for-equity uses FMV; debt-for-debt can use issue price, creating potential COD.","D014-S001 §108(e)(8),(10). \n3","Detailed issue-price regulations may be needed in actual transaction."],["D014-C043","A067","Recourse foreclosure can create separate disposition gain/loss and COD.","D014-S005, Pub. 4681 / Pub. 544. \n49","Deficiency retained versus cancelled changes amount."],["D014-C044","A067","Nonrecourse foreclosure generally puts full debt in amount realized and does not create separate COD.","D014-S009/S005. \n50","Character of disposition gain/loss still must be analyzed."],["D014-C045","A067","California generally recognizes cancelled debt income and, in final 2025 instructions, does not conform to federal principal-residence COD exclusion after 2017.","D014-S036/S037. \n51","Exact final 2026 CA return mechanics not verified."],["D014-C046","A067","FTB mortgage guidance calls for federal Form 982 copy and says California has no similar Form 982.","D014-S038. \n52","Tax-year/fact applicability must be checked."],["D014-C047","A067","Bankruptcy COD exclusion can transfer attribute-reduction consequences to bankruptcy estate in specified individual Ch. 7/11 cases.","§108(d)(8); Pub. 908. \n63","§1398 conditions apply."],["D014-C048","A019/A067","No universal verified rule was found that an accepted IRS OIC necessarily creates taxable COD or Form 1099-C on compromised tax balance.","Targeted IRS searches; general government-debt COD materials did not squarely resolve OIC tax-liability compromise. \n7","Unresolved/publication hold; do not infer either taxability or nontaxability."],["D014-C049","A067","Form 1099-C instructions say if an identifiable event occurs but debt is not actually discharged, income generally belongs in year of actual discharge.","D014-S007 recipient instructions. \n42","Other timing doctrines can require professional analysis."],["D014-C050","A067","Qualified farm debt requires direct farming connection, 50% three-year gross-receipts test and qualified creditor, subject to limits.","D014-S001 §108(g). \n3","Specialized business exclusion."],["D014-C051","A067","QRPBI exclusion is unavailable to C corporations and is limited by property/debt/basis conditions.","D014-S001 §108(a)(1)(D),(c). \n3","Election and basis reduction apply."]]},{"headers":["Assigned area / subtopic","Status","Findings / claims","Missing evidence or next action"],"index":7,"links":[],"rows":[["Assigned area / subtopic","Status","Findings / claims","Missing evidence or next action"],["A019 — Federal income-tax debt","Answered","C001–C017, C020, C028","Account-specific assessment/notice chronology always required."],["A019 — State income tax","Answered for California; partial nationwide","C021–C022","Build separate modules for every other state."],["A019 — Local income tax","Partial","Local-tax principle addressed; Orange has no general local personal income tax module developed here.","Research each locality that imposes local income tax."],["A019 — Federal payroll tax","Answered materially","C016, C018–C019","Detailed §6672 litigation defenses can be expanded."],["A019 — California payroll tax","Partial","C025","Open controlling EDD/UIC collection and responsible-person provisions."],["A019 — Sales/use tax","Answered for California; partial nationwide","C023–C024","Other states have different responsible-person, trust-tax and OIC rules."],["A019 — Property tax","Answered for Orange County exemplar; partial nationwide","C026","Each county/state foreclosure/redemption system differs."],["A019 — Business/local tax","Partial","C022–C025, C027","No nationwide municipal-tax matrix."],["A019 — Penalties","Answered federally; selected CA/local","C014–C017, C026–C027","Exact state/local penalties require jurisdictional modules."],["A019 — Interest","Answered for federal Q4 2026; CA EDD current period","C017, C025","Rates are time-sensitive and require refresh."],["A019 — Assessments/debt validity","Answered federally; CA FTB core","C009, C021","Full audit/reconsideration and every state appeal route not mapped."],["A019 — Liens","Answered federally; CA sales/property substantially addressed","C001–C002, C013, C023, C026","EDD and other-state lien statutes partial."],["A019 — Levies","Answered federally; CA CDTFA substantially addressed","C003, C012, C023","Exemption schedules and wrongful-levy litigation not comprehensively catalogued."],["A019 — Agreements/installments","Answered federally; CA examples","C006–C008, C022, C025–C026","Other states/localities unresolved."],["A019 — Offer in compromise","Answered federal; CA FTB/CDTFA material","C009–C010, C020, C022–C024","EDD complete OIC eligibility partial."],["A019 — Hardship","Answered federal; CA advocate path noted","C011–C012","State-specific hardship standards need separate modules."],["A019 — Appeals/litigation","Answered federal CDP/OIC core","C002–C004, C020–C021","Full deficiency litigation, refund suits and all state appellate routes outside this module."],["A019 — Bankruptcy alternative","Answered at issue-spotting level","C028","Tax-year-specific discharge calculator would require fuller §507/§523 matrix."],["A019 — Credit consequences","Unresolved intentionally","Publication hold","No support for universal credit-score effect; research exact CRA/scoring proposition before publishing one."],["A019 — Tribal law","Unresolved/not jurisdictionally assigned","Scope note","Need identified tribe and governing tax code."],["A067 — General COD income","Answered","C030–C033","Transaction-specific timing may require case law."],["A067 — 1099-C","Answered materially","C031–C032, C049","Complete issuer correction procedure could be separately expanded."],["A067 — Form 982","Answered materially","C035–C037, C046","Final detailed 2026 federal instructions not verified."],["A067 — Insolvency","Answered","C035","Complex contingent liabilities/assets may require case law."],["A067 — Bankruptcy exclusion","Answered","C034, C047","Individual bankruptcy facts remain case-specific."],["A067 — Tax attributes","Answered","C037, C047","Specialized attribute/basis elections can be expanded."],["A067 — Principal-residence debt","Answered federally; CA mismatch addressed","C038, C045–C046","2026 final CA instructions pending verification."],["A067 — Farm debt","Answered","C050","Specialized agricultural entities may need additional rules."],["A067 — Real-property business debt","Answered materially","C051","Detailed basis-election mechanics can be expanded."],["A067 — Student loans/current-year transition","Answered federally","C039","State treatment must be checked separately."],["A067 — Joint debt","Answered materially","C040","Community-property/joint-return permutations deserve state-specific expansion."],["A067 — Partnership/S corporation/business debt","Answered materially","C041–C042, C050–C051","C-corp, guarantor, related-party and complex debt-modification rules can be deeper standalone modules."],["A067 — Foreclosure/repo","Answered materially","C043–C044","Property character, §121, depreciation recapture and state law remain separate layers."],["A067 — Federal tax-debt compromise itself","Unresolved","C048","Need direct published authority before saying accepted IRS OIC remainder is or is not COD."],["A067 — State cancellation taxation","Answered for California 2025 final guidance; partial for 2026/all states","C045–C046","Refresh California when final 2026 instructions issue; state-by-state conformity survey required."],["A067 — Credit consequences","Unresolved intentionally","Publication hold","Form 1099-C tax reporting does not establish universal credit-reporting outcome."]]}],"claims":[{"claim_id":"D014-C001","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C001","Area":"A019","Precise claim":"Federal tax lien reaches all taxpayer property/rights after liability, demand and neglect/refusal; amount includes tax and statutory additions.","Primary/source support and pinpoint":"D014-S011, 26 U.S.C. §6321. \n8","Conditions / evidence limits":"Priority against third parties has additional rules not fully covered here."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S011"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C002","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C002","Area":"A019","Precise claim":"NFTL notice generally within five business days; CDP request has statutory 30-day framework.","Primary/source support and pinpoint":"D014-S012, §6320; IRS CDP guidance. \n10","Conditions / evidence limits":"Notice dates must be read from actual notice."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C003","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C003","Area":"A019","Precise claim":"Levy generally requires at least 30-day pre-levy CDP notice.","Primary/source support and pinpoint":"D014-S013, §6330. \n11","Conditions / evidence limits":"Statutory exceptions exist; not a universal bar to every collection measure."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C004","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C004","Area":"A019","Precise claim":"CDP Tax Court petition period is 30 days; Boechler makes it nonjurisdictional and equitably tollable.","Primary/source support and pinpoint":"D014-S013/S026. \n12","Conditions / evidence limits":"Equitable tolling is not automatic."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C005","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C005","Area":"A019","Precise claim":"General federal collection period is 10 years after assessment, subject to suspensions/extensions.","Primary/source support and pinpoint":"D014-S016. \n13","Conditions / evidence limits":"Never calculate CSED from assessment + 10 years without event history."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C006","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C006","Area":"A019","Precise claim":"§6159 authorizes IAs; statutory guaranteed IA uses ≤$10,000 tax-liability threshold and three-year full-pay condition plus other requirements.","Primary/source support and pinpoint":"D014-S015, §6159. \n14","Conditions / evidence limits":"Different from administrative Simple Payment Plan thresholds."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C007","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C007","Area":"A019","Precise claim":"PPIAs reviewed at least every two years.","Primary/source support and pinpoint":"D014-S015, §6159. \n14","Conditions / evidence limits":"Financial changes may matter."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C008","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C008","Area":"A019","Precise claim":"2026 Simple Plan criteria include $50k individual threshold and specified business thresholds; program changed effective May 31, 2026.","Primary/source support and pinpoint":"D014-S018/S019. \n4","Conditions / evidence limits":"Administrative program; can change."},"coordinator_verification_status":"chronology_correction_reviewed_selected_primary_scope_only","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S018","D014-S019","coordinator-D014-IA-history"],"finding":"May31 explicitly digitization/retention, not established program inception; current IRM July21, earlier interim stages. CSED/assessed balance/NFTL/TFRP limits essential.","area_acceptance":false},"previous_coordinator_status":"correction_required_effective_date_and_scope","coordinator_superseded_by":"[internal evidence reference]","coordinator_checked_at":"2026-10-23T01:25:05.873031+00:00"},{"claim_id":"D014-C009","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C009","Area":"A019","Precise claim":"OIC grounds include doubt as to liability, doubt as to collectibility and effective tax administration.","Primary/source support and pinpoint":"D014-S017, §7122 / Reg. §301.7122-1. \n2","Conditions / evidence limits":"Not every hardship qualifies for compromise."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["coordinator-D014-DATL","coordinator-D014-OIC-topic"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C010","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C010","Area":"A019","Precise claim":"OIC fee $205; lump offer ordinarily requires 20%; low-income exception exists.","Primary/source support and pinpoint":"D014-S020. \n15","Conditions / evidence limits":"Current program mechanics; not acceptance formula."},"coordinator_verification_status":"DATL_fee_path_correction_reviewed_eligibility_and_other_scope_held","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S020","coordinator-D014-DATL","coordinator-D014-OIC-terms","coordinator-D014-OIC-topic"],"finding":"No payment or fee with656-L DATL offer, separate from low-income exception. Label standard example and add payment-term months.","area_acceptance":false},"previous_coordinator_status":"correction_required_missing_DATL_exception","coordinator_superseded_by":"[internal evidence reference]","coordinator_checked_at":"2026-10-23T01:25:05.873031+00:00"},{"claim_id":"D014-C011","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C011","Area":"A019","Precise claim":"CNC can pause collection for hardship but does not forgive debt; P&I continue.","Primary/source support and pinpoint":"D014-S021. \n17","Conditions / evidence limits":"IRS can reassess ability to pay."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C012","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C012","Area":"A019","Precise claim":"§6343 requires levy release for specified conditions, including economic hardship.","Primary/source support and pinpoint":"D014-S014. \n18","Conditions / evidence limits":"Does not itself erase tax."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C013","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C013","Area":"A019","Precise claim":"Release, property discharge, subordination and NFTL withdrawal are legally distinct.","Primary/source support and pinpoint":"IRS lien guidance. \n9","Conditions / evidence limits":"Exact eligibility differs by remedy."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C014","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C014","Area":"A019","Precise claim":"FTP penalty ordinarily 0.5%/month, max 25%; qualifying approved-plan rate 0.25%; specified post-notice rate can reach 1%.","Primary/source support and pinpoint":"D014-S022. \n19","Conditions / evidence limits":"Exact monthly interaction depends on account."},"coordinator_verification_status":"selected_official_program_passage_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:28:52.500131+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S022"],"finding":"Qualifying timely individual/approved-plan and post-notice conditions retained; exact penalty model not certified.","area_acceptance":false}},{"claim_id":"D014-C015","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C015","Area":"A019","Precise claim":"FTF penalty ordinarily 5%/month, max 25%; >60-day minimum for returns required in 2026 is lesser of $525 or 100% tax.","Primary/source support and pinpoint":"D014-S022. \n20","Conditions / evidence limits":"Tax-year-specific minimum changes over time."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S022"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C016","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C016","Area":"A019","Precise claim":"Federal tax-deposit penalty tiers 2%/5%/10%/15%.","Primary/source support and pinpoint":"D014-S022. \n21","Conditions / evidence limits":"Deposit timing/notice controls tier."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C017","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C017","Area":"A019","Precise claim":"Q4 2026 ordinary federal underpayment interest rate is 7% annually.","Primary/source support and pinpoint":"D014-S023. \n57","Conditions / evidence limits":"Quarter-specific; must refresh."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S023","coordinator-D014-interest-table"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C018","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C018","Area":"A019","Precise claim":"TFRP reaches unpaid trust-fund portion; responsible/willful test; Letter 1153 appeal generally 60/75 days.","Primary/source support and pinpoint":"D014-S024. \n24","Conditions / evidence limits":"Person-specific factual inquiry."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C019","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C019","Area":"A019","Precise claim":"Multiple responsible persons may be assessed but trust-fund amount is collected only once; entity compromise may not end responsible-person exposure.","Primary/source support and pinpoint":"IRS IRM. \n26","Conditions / evidence limits":"Administrative guidance."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C020","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C020","Area":"A019","Precise claim":"Rejected OIC generally carries 30-day administrative appeal period.","Primary/source support and pinpoint":"IRS Appeals guidance. \n16","Conditions / evidence limits":"Actual rejection letter controls."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C021","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C021","Area":"A019","Precise claim":"California FTB NPA protest period is 60 days.","Primary/source support and pinpoint":"D014-S030 / R&TC §19041 agency guidance. \n29","Conditions / evidence limits":"Other CA appeal stages not exhaustively mapped."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C022","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C022","Area":"A019","Precise claim":"FTB OIC applies to qualifying final/undisputed liabilities after required returns and collection alternatives are addressed.","Primary/source support and pinpoint":"D014-S029. \n30","Conditions / evidence limits":"California only."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C023","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C023","Area":"A019","Precise claim":"CDTFA uses liens/levies and OIC; preliminary lien notice generally ≥30 days under current collection guidance.","Primary/source support and pinpoint":"D014-S031. \n32","Conditions / evidence limits":"Tax/program-specific."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C024","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C024","Area":"A019","Precise claim":"CDTFA FAQ describes reasonable collection period as typically four years in OIC evaluation.","Primary/source support and pinpoint":"D014-S031. \n34","Conditions / evidence limits":"Agency policy, not settlement guarantee."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C025","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C025","Area":"A019","Precise claim":"EDD provides account payment plans/OIC pathways; Jul.–Dec. 2026 interest 7%.","Primary/source support and pinpoint":"D014-S032/S033. \n35","Conditions / evidence limits":"Detailed EDD statutory collection rules partial."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C026","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C026","Area":"A019","Precise claim":"Orange secured property tax standard calendar uses 10% late penalties; second installment adds $23; redemption framework includes 1.5% monthly and five-year mechanisms.","Primary/source support and pinpoint":"D014-S034. \n36","Conditions / evidence limits":"Actual bill and deadline exceptions control."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C027","area_numbers":[19],"researcher_record":{"Claim ID":"D014-C027","Area":"A019","Precise claim":"City of Orange has separate business-license/TOT delinquency charges.","Primary/source support and pinpoint":"D014-S035. \n38","Conditions / evidence limits":"City-specific only."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C028","area_numbers":[19,67],"researcher_record":{"Claim ID":"D014-C028","Area":"A019/A067","Precise claim":"Some tax debt can be discharged in bankruptcy, many taxes are excepted, and valid liens can survive against property.","Primary/source support and pinpoint":"D014-S027/S028. \n27","Conditions / evidence limits":"Requires tax-year/date-specific §523/§507 analysis."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C030","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C030","Area":"A067","Precise claim":"COD is included in federal gross income absent exception/exclusion.","Primary/source support and pinpoint":"D014-S002/S001, §§61(a)(11), 108. \n39","Conditions / evidence limits":"Amount/timing can be complex."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S002"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C031","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C031","Area":"A067","Precise claim":"$600 is Form 1099-C reporting threshold, not federal taxable-income threshold.","Primary/source support and pinpoint":"D014-S003/S006/S007. \n40","Conditions / evidence limits":"Applicable-entity/identifiable-event rules also required."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S003"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C032","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C032","Area":"A067","Precise claim":"1099-C identifiable event does not itself resolve substantive taxability; no form does not eliminate taxable COD.","Primary/source support and pinpoint":"D014-S004/S005. \n41","Conditions / evidence limits":"Actual cancellation and §108 still control."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C033","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C033","Area":"A067","Precise claim":"Deductible-debt and qualifying purchase-money reduction rules can prevent COD treatment.","Primary/source support and pinpoint":"D014-S001, §108(e)(2),(5). \n3","Conditions / evidence limits":"Purchase-price rule has statutory conditions."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C034","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C034","Area":"A067","Precise claim":"COD discharged in Title 11 case can be excluded under §108(a)(1)(A).","Primary/source support and pinpoint":"D014-S001/S027. \n63","Conditions / evidence limits":"Discharge must fall within statutory bankruptcy rule."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S001"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C035","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C035","Area":"A067","Precise claim":"Insolvency = liabilities − FMV assets immediately before discharge; exclusion limited to insolvency amount.","Primary/source support and pinpoint":"D014-S001/S005. \n1","Conditions / evidence limits":"Asset/liability identification can be contested."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S001"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C036","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C036","Area":"A067","Precise claim":"§108 specifies priority among bankruptcy, insolvency, farm/QRPBI and QPRI exclusions.","Primary/source support and pinpoint":"D014-S001 §108(a)(2). \n3","Conditions / evidence limits":"Election can alter QPRI/insolvency ordering."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S001"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C037","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C037","Area":"A067","Precise claim":"Excluded COD can reduce NOLs, credits, capital losses, basis, passive attributes, foreign credits; specified credit reductions are 33⅓ cents/$1.","Primary/source support and pinpoint":"D014-S001/S010. \n3","Conditions / evidence limits":"Depends on exclusion and available attributes."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S001"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C038","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C038","Area":"A067","Precise claim":"QPRI exclusion is limited to pre-2026 discharge or pre-2026 written arrangement; debt cap $750k/$375k MFS.","Primary/source support and pinpoint":"D014-S001 §108(a)(1)(E),(h). \n3","Conditions / evidence limits":"Federal only; California does not mirror current federal rule."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S001"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C039","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C039","Area":"A067","Precise claim":"Broad 2021–2025 student-loan exclusion ended; current §108(f)(5) concerns death/disability, while service-program exclusions remain.","Primary/source support and pinpoint":"D014-S001 §108(f). \n3","Conditions / evidence limits":"Type of discharge matters."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S001"],"finding":"Full prose retains loan/SSN conditions and2026 transition; shortened claim table must retain necessary conditions when reused.","area_acceptance":false}},{"claim_id":"D014-C040","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C040","Area":"A067","Precise claim":"Joint debt is not automatically allocated by the full amount on each 1099-C or 50/50; facts and state law matter.","Primary/source support and pinpoint":"D014-S005. \n48","Conditions / evidence limits":"Joint return issues beyond IRS example not exhaustively analyzed."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C041","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C041","Area":"A067","Precise claim":"Partnership §108 analysis is generally partner-level; S-corporation analysis generally corporate-level.","Primary/source support and pinpoint":"D014-S001 §108(d)(6),(7); S039. \n47","Conditions / evidence limits":"Other entity/classification rules can affect result."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S001"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C042","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C042","Area":"A067","Precise claim":"Debt-for-equity uses FMV; debt-for-debt can use issue price, creating potential COD.","Primary/source support and pinpoint":"D014-S001 §108(e)(8),(10). \n3","Conditions / evidence limits":"Detailed issue-price regulations may be needed in actual transaction."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C043","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C043","Area":"A067","Precise claim":"Recourse foreclosure can create separate disposition gain/loss and COD.","Primary/source support and pinpoint":"D014-S005, Pub. 4681 / Pub. 544. \n49","Conditions / evidence limits":"Deficiency retained versus cancelled changes amount."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C044","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C044","Area":"A067","Precise claim":"Nonrecourse foreclosure generally puts full debt in amount realized and does not create separate COD.","Primary/source support and pinpoint":"D014-S009/S005. \n50","Conditions / evidence limits":"Character of disposition gain/loss still must be analyzed."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C045","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C045","Area":"A067","Precise claim":"California generally recognizes cancelled debt income and, in final 2025 instructions, does not conform to federal principal-residence COD exclusion after 2017.","Primary/source support and pinpoint":"D014-S036/S037. \n51","Conditions / evidence limits":"Exact final 2026 CA return mechanics not verified."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C046","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C046","Area":"A067","Precise claim":"FTB mortgage guidance calls for federal Form 982 copy and says California has no similar Form 982.","Primary/source support and pinpoint":"D014-S038. \n52","Conditions / evidence limits":"Tax-year/fact applicability must be checked."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C047","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C047","Area":"A067","Precise claim":"Bankruptcy COD exclusion can transfer attribute-reduction consequences to bankruptcy estate in specified individual Ch. 7/11 cases.","Primary/source support and pinpoint":"§108(d)(8); Pub. 908. \n63","Conditions / evidence limits":"§1398 conditions apply."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C048","area_numbers":[19,67],"researcher_record":{"Claim ID":"D014-C048","Area":"A019/A067","Precise claim":"No universal verified rule was found that an accepted IRS OIC necessarily creates taxable COD or Form 1099-C on compromised tax balance.","Primary/source support and pinpoint":"Targeted IRS searches; general government-debt COD materials did not squarely resolve OIC tax-liability compromise. \n7","Conditions / evidence limits":"Unresolved/publication hold; do not infer either taxability or nontaxability."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C049","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C049","Area":"A067","Precise claim":"Form 1099-C instructions say if an identifiable event occurs but debt is not actually discharged, income generally belongs in year of actual discharge.","Primary/source support and pinpoint":"D014-S007 recipient instructions. \n42","Conditions / evidence limits":"Other timing doctrines can require professional analysis."},"coordinator_verification_status":"not_yet_checked"},{"claim_id":"D014-C050","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C050","Area":"A067","Precise claim":"Qualified farm debt requires direct farming connection, 50% three-year gross-receipts test and qualified creditor, subject to limits.","Primary/source support and pinpoint":"D014-S001 §108(g). \n3","Conditions / evidence limits":"Specialized business exclusion."},"coordinator_verification_status":"selected_primary_passages_supported_with_limits","coordinator_review":{"checked_at":"2026-10-22T23:25:30.042416+00:00","review":"[internal evidence reference]","source_check_record":"[internal evidence reference]","source_ids":["D014-S001"],"finding":"Scoped textual check; remaining exception/application/source review open.","area_acceptance":false}},{"claim_id":"D014-C051","area_numbers":[67],"researcher_record":{"Claim ID":"D014-C051","Area":"A067","Precise claim":"QRPBI exclusion is unavailable to C corporations and is limited by property/debt/basis conditions.","Primary/source support and pinpoint":"D014-S001 §108(a)(1)(D),(c). \n3","Conditions / evidence limits":"Election and basis reduction apply."},"coordinator_verification_status":"not_yet_checked"}],"sources":[{"source_id":"D014-S001","urls":["https://uscode.house.gov/us/usc/119-118/t26/s108/"],"researcher_record":{"Source ID":"D014-S001","Source, issuer, direct URL":"26 U.S.C. §108, Income from discharge of indebtedness, U.S. House Office of Law Revision Counsel. https://uscode.house.gov/us/usc/119-118/t26/s108/ \n1","Pinpoint / version / status":"§§108(a), (b), (c), (d), (e), (f), (g), (h); current snapshot includes 2025 amendment notes and Jan. 1, 2026 QPRI transition.","Scope, access method, limits":"Federal; HTML opened/read by pinpoint. Primary controlling statute."},"coordinator_verification_status":"selected_passages_checked_with_limits","coordinator_check":{"checked_at":"2026-10-22T23:25:30.042416+00:00","record":"[internal evidence reference]","pinpoints":["108(a)(1)-(3),(b)(2)-(4),(d)(2)-(3),(6)-(7),(f)(5),(g),(h);2025 effective-date note"]}},{"source_id":"D014-S002","urls":["https://uscode.house.gov/","https://uscode.house.gov/us/usc/119-118/t26/s61/"],"researcher_record":{"Source ID":"D014-S002","Source, issuer, direct URL":"26 U.S.C. §61, U.S. House OLRC. https://uscode.house.gov/ — §61(a)(11). \n39","Pinpoint / version / status":"Gross income includes discharge-of-indebtedness income.","Scope, access method, limits":"Federal; primary statute, fetched/read."},"coordinator_verification_status":"selected_passages_checked_with_limits","coordinator_check":{"checked_at":"2026-10-22T23:25:30.042416+00:00","record":"[internal evidence reference]","pinpoints":["61(a)(11)"]},"coordinator_url_recovery":{"checked_at":"2026-10-22T23:25:30.042416+00:00","method":"Actual direct official document opened/read or explicitly documented same-pass reuse; homepage and researcher cells retained.","record":"[internal evidence reference]"}},{"source_id":"D014-S003","urls":["https://uscode.house.gov/","https://uscode.house.gov/us/usc/119-118/t26/s6050P/"],"researcher_record":{"Source ID":"D014-S003","Source, issuer, direct URL":"26 U.S.C. §6050P, U.S. House OLRC. https://uscode.house.gov/ — §6050P. \n40","Pinpoint / version / status":"$600 information-reporting rule; debtor statements. Current through Oct. 2026 code update identified in source.","Scope, access method, limits":"Federal; primary statute. Reporting, not substantive income exclusion."},"coordinator_verification_status":"selected_passages_checked_with_limits","coordinator_check":{"checked_at":"2026-10-22T23:25:30.042416+00:00","record":"[internal evidence reference]","pinpoints":["6050P(a)-(c)"]},"coordinator_url_recovery":{"checked_at":"2026-10-22T23:25:30.042416+00:00","method":"Actual direct official document opened/read or explicitly documented same-pass reuse; homepage and researcher cells retained.","record":"[internal evidence reference]"}},{"source_id":"D014-S004","urls":["https://www.ecfr.gov/current/title-26/section-1.6050P-1"],"researcher_record":{"Source ID":"D014-S004","Source, issuer, direct URL":"26 C.F.R. §1.6050P-1, Treasury/IRS, eCFR. https://www.ecfr.gov/current/title-26/section-1.6050P-1 \n41","Pinpoint / version / status":"Identifiable events for Form 1099-C.","Scope, access method, limits":"Federal; current regulation; HTML fetched/read."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S005","urls":["https://www.irs.gov/publications/p4681"],"researcher_record":{"Source ID":"D014-S005","Source, issuer, direct URL":"Publication 4681 (2025), Canceled Debts, Foreclosures, Repossessions, and Abandonments, IRS. https://www.irs.gov/publications/p4681 \n45","Pinpoint / version / status":"Insolvency; joint debt; recourse/nonrecourse; 1099-C; 2025 tax year.","Scope, access method, limits":"Federal administrative guidance; HTML opened/searched by passage. Latest final annual Pub. 4681 located, but 2025 tax year rather than final 2026 edition."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S006","urls":["https://www.irs.gov/forms-pubs/about-form-1099-c"],"researcher_record":{"Source ID":"D014-S006","Source, issuer, direct URL":"About Form 1099-C, IRS. https://www.irs.gov/forms-pubs/about-form-1099-c \n54","Pinpoint / version / status":"Updated Mar. 30, 2026; $600 filing trigger.","Scope, access method, limits":"Federal, current agency page."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S007","urls":["https://www.irs.gov/pub/irs-pdf/f1099c.pdf","https://www.irs.gov/pub/irs-pdf/i1099ac.pdf"],"researcher_record":{"Source ID":"D014-S007","Source, issuer, direct URL":"Form 1099-C / Instructions for Forms 1099-A and 1099-C, IRS. https://www.irs.gov/pub/irs-pdf/f1099c.pdf and https://www.irs.gov/pub/irs-pdf/i1099ac.pdf \n42","Pinpoint / version / status":"Rev. Apr. 2025; recipient instructions include actual-discharge timing warning.","Scope, access method, limits":"Federal; PDF text fetched. Form version remains operative material located in 2026 but revision is Apr. 2025."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S008","urls":["https://www.irs.gov/forms-pubs/about-form-982"],"researcher_record":{"Source ID":"D014-S008","Source, issuer, direct URL":"About Form 982, IRS. https://www.irs.gov/forms-pubs/about-form-982 \n5","Pinpoint / version / status":"Updated Aug. 27, 2026.","Scope, access method, limits":"Federal; current landing page. Detailed separate instructions located were older, a noted limit."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S009","urls":["https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR36dbe7d18edf3fe"],"researcher_record":{"Source ID":"D014-S009","Source, issuer, direct URL":"26 C.F.R. §1.1001-2, Discharge of liabilities, Treasury/eCFR. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR36dbe7d18edf3fe \n50","Pinpoint / version / status":"§1.1001-2(a), amount realized includes liabilities from which transferor is discharged.","Scope, access method, limits":"Federal; controlling regulation; HTML read."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S010","urls":["https://www.ecfr.gov/current/title-26/"],"researcher_record":{"Source ID":"D014-S010","Source, issuer, direct URL":"26 C.F.R. §§1.108-7 and 1.1017-1, Treasury/eCFR. https://www.ecfr.gov/current/title-26/ \n55","Pinpoint / version / status":"Attribute and basis reductions.","Scope, access method, limits":"Federal; current regulations fetched/read."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S011","urls":["https://uscode.house.gov/","https://uscode.house.gov/us/usc/119-118/t26/s6321/"],"researcher_record":{"Source ID":"D014-S011","Source, issuer, direct URL":"26 U.S.C. §6321, U.S. House OLRC. https://uscode.house.gov/ — §6321. \n8","Pinpoint / version / status":"Statutory lien after demand; tax, interest, additions, penalties, costs; all property/rights.","Scope, access method, limits":"Federal; controlling statute."},"coordinator_verification_status":"selected_passages_checked_with_limits","coordinator_check":{"checked_at":"2026-10-22T23:25:30.042416+00:00","record":"[internal evidence reference]","pinpoints":["6321; reused fresh D028 named-passage check from same coordinator pass"]},"coordinator_url_recovery":{"checked_at":"2026-10-22T23:25:30.042416+00:00","method":"Actual direct official document opened/read or explicitly documented same-pass reuse; homepage and researcher cells retained.","record":"[internal evidence reference]"}},{"source_id":"D014-S012","urls":["https://uscode.house.gov/"],"researcher_record":{"Source ID":"D014-S012","Source, issuer, direct URL":"26 U.S.C. §6320, U.S. House OLRC. https://uscode.house.gov/ — §6320. \n10","Pinpoint / version / status":"NFTL notice/CDP process; five-business-day statutory notice framework.","Scope, access method, limits":"Federal; controlling statute."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S013","urls":["https://uscode.house.gov/"],"researcher_record":{"Source ID":"D014-S013","Source, issuer, direct URL":"26 U.S.C. §6330, U.S. House OLRC. https://uscode.house.gov/ — §6330. \n11","Pinpoint / version / status":"Pre-levy CDP; 30-day notice; Tax Court review.","Scope, access method, limits":"Federal; controlling statute."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S014","urls":["https://uscode.house.gov/"],"researcher_record":{"Source ID":"D014-S014","Source, issuer, direct URL":"26 U.S.C. §6343, U.S. House OLRC. https://uscode.house.gov/ — §6343. \n18","Pinpoint / version / status":"Mandatory levy release conditions and hardship.","Scope, access method, limits":"Federal; controlling statute."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S015","urls":["https://uscode.house.gov/"],"researcher_record":{"Source ID":"D014-S015","Source, issuer, direct URL":"26 U.S.C. §6159, U.S. House OLRC. https://uscode.house.gov/ — §6159. \n14","Pinpoint / version / status":"Installment agreements; guaranteed $10,000 provision; termination; PPIA review.","Scope, access method, limits":"Federal; controlling statute."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S016","urls":["https://uscode.house.gov/"],"researcher_record":{"Source ID":"D014-S016","Source, issuer, direct URL":"26 U.S.C. §6502, U.S. House OLRC. https://uscode.house.gov/ — §6502. \n13","Pinpoint / version / status":"General 10-year collection period after assessment.","Scope, access method, limits":"Federal; statute. Actual CSED requires suspension/extension analysis."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S017","urls":["https://uscode.house.gov/","https://www.ecfr.gov/current/title-26/section-301.7122-1"],"researcher_record":{"Source ID":"D014-S017","Source, issuer, direct URL":"26 U.S.C. §7122 / Treas. Reg. §301.7122-1, Congress/Treasury. https://uscode.house.gov/ and https://www.ecfr.gov/current/title-26/section-301.7122-1 \n2","Pinpoint / version / status":"Compromise authority; doubt as to liability, collectibility, effective tax administration.","Scope, access method, limits":"Federal primary statute/regulation."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S018","urls":["https://www.irs.gov/payments/simple-payment-plans-for-individuals-and-businesses"],"researcher_record":{"Source ID":"D014-S018","Source, issuer, direct URL":"Simple Payment Plans, IRS. https://www.irs.gov/payments/simple-payment-plans-for-individuals-and-businesses \n4","Pinpoint / version / status":"Current 2026 administrative balance thresholds.","Scope, access method, limits":"Federal agency program; policy can change without statute."},"coordinator_verification_status":"selected_passages_checked_with_limits","coordinator_check":{"checked_at":"2026-10-22T23:25:30.042416+00:00","record":"[internal evidence reference]","pinpoints":["Generally how to qualify; Terms"]}},{"source_id":"D014-S019","urls":["https://www.irs.gov/irm/","https://www.irs.gov/irm/part5/irm_05-014-005"],"researcher_record":{"Source ID":"D014-S019","Source, issuer, direct URL":"IRM Simple Payment Plan update, IRS. https://www.irs.gov/irm/ \n56","Pinpoint / version / status":"IRM updated July 23, 2026; May 31, 2026 effective change replacing streamlined framework.","Scope, access method, limits":"Federal internal administrative guidance; not statute."},"coordinator_verification_status":"selected_passages_checked_with_limits","coordinator_check":{"checked_at":"2026-10-22T23:25:30.042416+00:00","record":"[internal evidence reference]","pinpoints":["Manual Transmittal July21 2026; Effect on Other Documents;5.14.5.2,.4,.5(7)"]},"coordinator_url_recovery":{"checked_at":"2026-10-22T23:25:30.042416+00:00","method":"Actual direct official document opened/read or explicitly documented same-pass reuse; homepage and researcher cells retained.","record":"[internal evidence reference]"}},{"source_id":"D014-S020","urls":["https://www.irs.gov/payments/offer-in-compromise"],"researcher_record":{"Source ID":"D014-S020","Source, issuer, direct URL":"Offer in Compromise, IRS. https://www.irs.gov/payments/offer-in-compromise \n15","Pinpoint / version / status":"$205 fee; 20% lump-sum initial payment; payment alternatives/low-income exception.","Scope, access method, limits":"Federal current program guidance."},"coordinator_verification_status":"selected_passages_checked_with_limits","coordinator_check":{"checked_at":"2026-10-22T23:25:30.042416+00:00","record":"[internal evidence reference]","pinpoints":["Eligibility; fee/first payment/lump sum"]}},{"source_id":"D014-S021","urls":["https://www.irs.gov/businesses/small-businesses-self-employed/temporarily-delay-the-collection-process"],"researcher_record":{"Source ID":"D014-S021","Source, issuer, direct URL":"Currently-not-collectible / temporary collection delay, IRS. https://www.irs.gov/businesses/small-businesses-self-employed/temporarily-delay-the-collection-process \n17","Pinpoint / version / status":"Current July 2026-era page; hardship, no forgiveness, continuing P&I.","Scope, access method, limits":"Federal agency guidance."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S022","urls":["https://www.irs.gov/payments/failure-to-pay-penalty","https://www.irs.gov/payments/failure-to-file-penalty"],"researcher_record":{"Source ID":"D014-S022","Source, issuer, direct URL":"Failure-to-pay / failure-to-file / deposit-penalty guidance, IRS. https://www.irs.gov/payments/failure-to-pay-penalty and related IRS penalty pages. \n19","Pinpoint / version / status":"Current 2026 rates cited in report.","Scope, access method, limits":"Federal agency guidance; exact calculation remains return/account specific."},"coordinator_verification_status":"selected_passages_checked_with_limits","coordinator_check":{"checked_at":"2026-10-22T23:25:30.042416+00:00","record":"[internal evidence reference]","pinpoints":["Forms1040/1120 computation, minimum table, same-month interaction"]}},{"source_id":"D014-S023","urls":["https://www.irs.gov/irb/2026-36_irb"],"researcher_record":{"Source ID":"D014-S023","Source, issuer, direct URL":"Federal tax interest rate Q4 2026 / Rev. Rul. 2026-15, IRS. \n57","Pinpoint / version / status":"Q4 2026 underpayment rate 7% for ordinary individual underpayments.","Scope, access method, limits":"Federal; quarter-specific. Must refresh each quarter."},"coordinator_verification_status":"selected_passages_checked_with_limits","coordinator_check":{"checked_at":"2026-10-22T23:25:30.042416+00:00","record":"[internal evidence reference]","pinpoints":["Rev Rul2026-15, operative paragraph, printed216; interest factors reference"]},"coordinator_url_recovery":{"checked_at":"2026-10-22T23:25:30.042416+00:00","method":"Actual direct official document opened/read or explicitly documented same-pass reuse; homepage and researcher cells retained.","record":"[internal evidence reference]"}},{"source_id":"D014-S024","urls":["https://www.irs.gov/businesses/small-businesses-self-employed/trust-fund-recovery-penalty"],"researcher_record":{"Source ID":"D014-S024","Source, issuer, direct URL":"Trust Fund Recovery Penalty guidance, IRS. https://www.irs.gov/businesses/small-businesses-self-employed/trust-fund-recovery-penalty \n24","Pinpoint / version / status":"§6672 responsible/willful standards; trust-fund amount; Letter 1153 appeal period.","Scope, access method, limits":"Federal administrative guidance interpreting statute; entity/person-specific analysis needed."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S025","urls":["https://www.irs.gov/appeals/collection-due-process-cdp-faqs"],"researcher_record":{"Source ID":"D014-S025","Source, issuer, direct URL":"Collection Due Process FAQs / Form 12153 guidance, IRS. https://www.irs.gov/appeals/collection-due-process-cdp-faqs \n58","Pinpoint / version / status":"30-day CDP periods; equivalent-hearing consequences.","Scope, access method, limits":"Federal administrative procedure."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S026","urls":["https://www.supremecourt.gov/opinions/21pdf/20-1472_6j37.pdf"],"researcher_record":{"Source ID":"D014-S026","Source, issuer, direct URL":"Boechler, P.C. v. Commissioner, No. 20-1472, U.S. Supreme Court, Apr. 21, 2022. https://www.supremecourt.gov/opinions/21pdf/20-1472_6j37.pdf \n12","Pinpoint / version / status":"Slip op. syllabus and pp. 2–11; §6330(d)(1) deadline nonjurisdictional and equitably tollable.","Scope, access method, limits":"Federal controlling case; PDF screenshot/read, not discovery-only."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S027","urls":["https://www.irs.gov/publications/p908"],"researcher_record":{"Source ID":"D014-S027","Source, issuer, direct URL":"Publication 908 (2025), Bankruptcy Tax Guide, IRS. https://www.irs.gov/publications/p908 \n27","Pinpoint / version / status":"Tax dischargeability, liens, §507 timing, COD in bankruptcy.","Scope, access method, limits":"Federal agency guidance; bankruptcy outcomes require Bankruptcy Code analysis and individual dates."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S028","urls":["https://www.uscourts.gov/court-programs/bankruptcy/bankruptcy-basics/chapter-7-bankruptcy-basics"],"researcher_record":{"Source ID":"D014-S028","Source, issuer, direct URL":"Chapter 7 / Chapter 13 Bankruptcy Basics, U.S. Courts. https://www.uscourts.gov/court-programs/bankruptcy/bankruptcy-basics/chapter-7-bankruptcy-basics \n28","Pinpoint / version / status":"Discharge and statutory exceptions including certain taxes.","Scope, access method, limits":"Federal judiciary educational material; not substitute for Code/case-specific analysis."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S029","urls":["https://www.ftb.ca.gov/pay/if-you-cant-pay/offer-in-compromise.html"],"researcher_record":{"Source ID":"D014-S029","Source, issuer, direct URL":"FTB Offer in Compromise, California Franchise Tax Board. https://www.ftb.ca.gov/pay/if-you-cant-pay/offer-in-compromise.html \n30","Pinpoint / version / status":"Final/undisputed liability, filing/compliance prerequisites.","Scope, access method, limits":"California income/franchise tax administrative program."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S030","urls":["https://www.ftb.ca.gov/forms/misc/7275.html","https://www.ftb.ca.gov/forms/misc/7275.html?utm_source=chatgpt.com","https://www.ftb.ca.gov/forms/misc/4058C.html","https://www.ftb.ca.gov/forms/misc/4058C.html?utm_source=chatgpt.com","https://www.ftb.ca.gov/forms/misc/1140.html","https://www.ftb.ca.gov/forms/misc/1140.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"D014-S030","Source, issuer, direct URL":"FTB NPA/protest guidance, California Franchise Tax Board. \n29","Pinpoint / version / status":"60-day NPA protest; installment-agreement rejection review.","Scope, access method, limits":"California; agency guidance referencing R&TC §§19041–19042."},"coordinator_verification_status":"bundle_locator_recovered_selected_components_checked_remaining_primary_or_access_held","coordinator_url_recovery":{"at":"2026-10-23T03:42:48.503172+00:00","evidence":"[internal evidence reference]","method":"Subsequentcomponent-sourceURLs;someopened,somediscovery/failed. Originalsessionaccessnotverified."},"coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"D014-S031","urls":["https://www.cdtfa.ca.gov/taxes-and-fees/offer-in-compromise.htm"],"researcher_record":{"Source ID":"D014-S031","Source, issuer, direct URL":"CDTFA Offer in Compromise / Collection Procedures, California Department of Tax and Fee Administration. https://www.cdtfa.ca.gov/taxes-and-fees/offer-in-compromise.htm \n33","Pinpoint / version / status":"OIC; typical four-year collectibility policy; active-business rule through Jan. 1, 2028; liens/levies.","Scope, access method, limits":"California sales/use and CDTFA-administered taxes. Four-year statement is agency policy, not universal statutory settlement period."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S032","urls":["https://edd.ca.gov/en/payroll_taxes/","https://edd.ca.gov/en/payroll_taxes/e-Services_for_Business/"],"researcher_record":{"Source ID":"D014-S032","Source, issuer, direct URL":"EDD Payroll Taxes / e-Services for Business, California EDD. https://edd.ca.gov/en/payroll_taxes/ and https://edd.ca.gov/en/payroll_taxes/e-Services_for_Business/ \n59","Pinpoint / version / status":"Payment-plan access; Multi-Agency OIC form listing.","Scope, access method, limits":"California payroll tax; collection-law detail only partially researched."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S033","urls":["https://edd.ca.gov/en/payroll_Taxes/Interest_Rate","https://edd.ca.gov/en/payroll_Taxes/Interest_Rate?utm_source=chatgpt.com","https://edd.ca.gov/en/payroll_taxes/employer-news/","https://edd.ca.gov/en/payroll_taxes/employer-news/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"D014-S033","Source, issuer, direct URL":"EDD payroll-tax interest rate, California EDD. \n60","Pinpoint / version / status":"July–Dec. 2026: 7%.","Scope, access method, limits":"California payroll tax; period-specific."},"coordinator_verification_status":"bundle_locator_recovered_selected_components_checked_remaining_primary_or_access_held","coordinator_url_recovery":{"at":"2026-10-23T03:42:48.503172+00:00","evidence":"[internal evidence reference]","method":"Subsequentcomponent-sourceURLs;someopened,somediscovery/failed. Originalsessionaccessnotverified."},"coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"D014-S034","urls":["https://octreasurer.gov/property-tax/informationfaqs/important-dates","https://octreasurer.gov/property-tax/informationfaqs/important-dates?utm_source=chatgpt.com","https://www.octreasurer.gov/PaymentPlans","https://www.octreasurer.gov/PaymentPlans?utm_source=chatgpt.com","https://octreasurer.com/sites/ttc/files/2022-03/5payplan.pdf","https://octreasurer.com/sites/ttc/files/2022-03/5payplan.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"D014-S034","Source, issuer, direct URL":"Orange County Property Tax Important Dates / Five-Year Payment Plan, Orange County Treasurer-Tax Collector. \n36","Pinpoint / version / status":"Nov. 1/Dec. 10; Feb. 1/Apr. 10; penalties; default/redemption and power-to-sell framework.","Scope, access method, limits":"Orange County, California; property tax only. Actual tax bill/calendar and statutory exceptions control."},"coordinator_verification_status":"bundle_locator_recovered_selected_components_checked_remaining_primary_or_access_held","coordinator_url_recovery":{"at":"2026-10-23T03:42:48.503172+00:00","evidence":"[internal evidence reference]","method":"Subsequentcomponent-sourceURLs;someopened,somediscovery/failed. Originalsessionaccessnotverified."},"coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"D014-S035","urls":["https://www.cityoforange.org/our-city/departments/finance/business-license-information/faqs","https://www.cityoforange.org/our-city/departments/finance/business-license-information/faqs?utm_source=chatgpt.com","https://ecode360.com/43558935","https://ecode360.com/43558935?utm_source=chatgpt.com","https://www.cityoforange.org/our-city/departments/finance/hotel-transient-occupancy-tax","https://www.cityoforange.org/our-city/departments/finance/hotel-transient-occupancy-tax?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"D014-S035","Source, issuer, direct URL":"City of Orange business-license and transient-occupancy-tax guidance, City of Orange. \n38","Pinpoint / version / status":"Local delinquency penalties/interest.","Scope, access method, limits":"City of Orange only; not countywide or statewide."},"coordinator_verification_status":"bundle_locator_recovered_selected_components_checked_remaining_primary_or_access_held","coordinator_url_recovery":{"at":"2026-10-23T03:42:48.503172+00:00","evidence":"[internal evidence reference]","method":"Subsequentcomponent-sourceURLs;someopened,somediscovery/failed. Originalsessionaccessnotverified."},"coordinator_check_evidence":"[internal evidence reference]"},{"source_id":"D014-S036","urls":["https://www.ftb.ca.gov/file/personal/income-types/information-returns-1099.html"],"researcher_record":{"Source ID":"D014-S036","Source, issuer, direct URL":"FTB 1099 guidance for recipients, California Franchise Tax Board. https://www.ftb.ca.gov/file/personal/income-types/information-returns-1099.html \n51","Pinpoint / version / status":"Updated June 10, 2026; cancelled debt generally income.","Scope, access method, limits":"California individual tax guidance."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S037","urls":["https://www.ftb.ca.gov/forms/2025/2025-540-ca-instructions.html"],"researcher_record":{"Source ID":"D014-S037","Source, issuer, direct URL":"2025 Schedule CA (540) Instructions, California FTB. https://www.ftb.ca.gov/forms/2025/2025-540-ca-instructions.html \n6","Pinpoint / version / status":"Principal-residence COD federal nonconformity after Dec. 31, 2017.","Scope, access method, limits":"Final 2025 state-return instructions. Exact 2026 line mechanics remain unverified."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S038","urls":["https://www.ftb.ca.gov/file/personal/income-types/mortgage-forgiveness-debt-relief.html"],"researcher_record":{"Source ID":"D014-S038","Source, issuer, direct URL":"Mortgage forgiveness debt relief, California FTB. https://www.ftb.ca.gov/file/personal/income-types/mortgage-forgiveness-debt-relief.html \n52","Pinpoint / version / status":"Updated Dec. 17, 2025; federal Form 982 copy; no similar CA form.","Scope, access method, limits":"California; applicability depends on tax year/facts."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S039","urls":["https://www.irs.gov/instructions/i1065"],"researcher_record":{"Source ID":"D014-S039","Source, issuer, direct URL":"2025 Instructions for Form 1065, IRS. https://www.irs.gov/instructions/i1065 \n61","Pinpoint / version / status":"Partnership COD separately stated; partner §108 treatment.","Scope, access method, limits":"Federal administrative return guidance; complements §108(d)(6)."},"coordinator_verification_status":"not_yet_checked"},{"source_id":"D014-S040","urls":["https://www.irs.gov/payments/penalty-relief-for-reasonable-cause"],"researcher_record":{"Source ID":"D014-S040","Source, issuer, direct URL":"Reasonable-cause penalty relief, IRS. https://www.irs.gov/payments/penalty-relief-for-reasonable-cause \n23","Pinpoint / version / status":"Updated June 21, 2026.","Scope, access method, limits":"Federal administrative penalty relief; fact-specific."},"coordinator_verification_status":"not_yet_checked"}],"coverage":[{"topic":"A019 — Federal income-tax debt","researcher_record":{"Assigned area / subtopic":"A019 — Federal income-tax debt","Status":"Answered","Findings / claims":"C001–C017, C020, C028","Missing evidence or next action":"Account-specific assessment/notice chronology always required."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — State income tax","researcher_record":{"Assigned area / subtopic":"A019 — State income tax","Status":"Answered for California; partial nationwide","Findings / claims":"C021–C022","Missing evidence or next action":"Build separate modules for every other state."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Local income tax","researcher_record":{"Assigned area / subtopic":"A019 — Local income tax","Status":"Partial","Findings / claims":"Local-tax principle addressed; Orange has no general local personal income tax module developed here.","Missing evidence or next action":"Research each locality that imposes local income tax."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Federal payroll tax","researcher_record":{"Assigned area / subtopic":"A019 — Federal payroll tax","Status":"Answered materially","Findings / claims":"C016, C018–C019","Missing evidence or next action":"Detailed §6672 litigation defenses can be expanded."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — California payroll tax","researcher_record":{"Assigned area / subtopic":"A019 — California payroll tax","Status":"Partial","Findings / claims":"C025","Missing evidence or next action":"Open controlling EDD/UIC collection and responsible-person provisions."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Sales/use tax","researcher_record":{"Assigned area / subtopic":"A019 — Sales/use tax","Status":"Answered for California; partial nationwide","Findings / claims":"C023–C024","Missing evidence or next action":"Other states have different responsible-person, trust-tax and OIC rules."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Property tax","researcher_record":{"Assigned area / subtopic":"A019 — Property tax","Status":"Answered for Orange County exemplar; partial nationwide","Findings / claims":"C026","Missing evidence or next action":"Each county/state foreclosure/redemption system differs."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Business/local tax","researcher_record":{"Assigned area / subtopic":"A019 — Business/local tax","Status":"Partial","Findings / claims":"C022–C025, C027","Missing evidence or next action":"No nationwide municipal-tax matrix."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Penalties","researcher_record":{"Assigned area / subtopic":"A019 — Penalties","Status":"Answered federally; selected CA/local","Findings / claims":"C014–C017, C026–C027","Missing evidence or next action":"Exact state/local penalties require jurisdictional modules."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Interest","researcher_record":{"Assigned area / subtopic":"A019 — Interest","Status":"Answered for federal Q4 2026; CA EDD current period","Findings / claims":"C017, C025","Missing evidence or next action":"Rates are time-sensitive and require refresh."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Assessments/debt validity","researcher_record":{"Assigned area / subtopic":"A019 — Assessments/debt validity","Status":"Answered federally; CA FTB core","Findings / claims":"C009, C021","Missing evidence or next action":"Full audit/reconsideration and every state appeal route not mapped."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Liens","researcher_record":{"Assigned area / subtopic":"A019 — Liens","Status":"Answered federally; CA sales/property substantially addressed","Findings / claims":"C001–C002, C013, C023, C026","Missing evidence or next action":"EDD and other-state lien statutes partial."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Levies","researcher_record":{"Assigned area / subtopic":"A019 — Levies","Status":"Answered federally; CA CDTFA substantially addressed","Findings / claims":"C003, C012, C023","Missing evidence or next action":"Exemption schedules and wrongful-levy litigation not comprehensively catalogued."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Agreements/installments","researcher_record":{"Assigned area / subtopic":"A019 — Agreements/installments","Status":"Answered federally; CA examples","Findings / claims":"C006–C008, C022, C025–C026","Missing evidence or next action":"Other states/localities unresolved."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Offer in compromise","researcher_record":{"Assigned area / subtopic":"A019 — Offer in compromise","Status":"Answered federal; CA FTB/CDTFA material","Findings / claims":"C009–C010, C020, C022–C024","Missing evidence or next action":"EDD complete OIC eligibility partial."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Hardship","researcher_record":{"Assigned area / subtopic":"A019 — Hardship","Status":"Answered federal; CA advocate path noted","Findings / claims":"C011–C012","Missing evidence or next action":"State-specific hardship standards need separate modules."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Appeals/litigation","researcher_record":{"Assigned area / subtopic":"A019 — Appeals/litigation","Status":"Answered federal CDP/OIC core","Findings / claims":"C002–C004, C020–C021","Missing evidence or next action":"Full deficiency litigation, refund suits and all state appellate routes outside this module."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Bankruptcy alternative","researcher_record":{"Assigned area / subtopic":"A019 — Bankruptcy alternative","Status":"Answered at issue-spotting level","Findings / claims":"C028","Missing evidence or next action":"Tax-year-specific discharge calculator would require fuller §507/§523 matrix."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Credit consequences","researcher_record":{"Assigned area / subtopic":"A019 — Credit consequences","Status":"Unresolved intentionally","Findings / claims":"Publication hold","Missing evidence or next action":"No support for universal credit-score effect; research exact CRA/scoring proposition before publishing one."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A019 — Tribal law","researcher_record":{"Assigned area / subtopic":"A019 — Tribal law","Status":"Unresolved/not jurisdictionally assigned","Findings / claims":"Scope note","Missing evidence or next action":"Need identified tribe and governing tax code."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — General COD income","researcher_record":{"Assigned area / subtopic":"A067 — General COD income","Status":"Answered","Findings / claims":"C030–C033","Missing evidence or next action":"Transaction-specific timing may require case law."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — 1099-C","researcher_record":{"Assigned area / subtopic":"A067 — 1099-C","Status":"Answered materially","Findings / claims":"C031–C032, C049","Missing evidence or next action":"Complete issuer correction procedure could be separately expanded."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Form 982","researcher_record":{"Assigned area / subtopic":"A067 — Form 982","Status":"Answered materially","Findings / claims":"C035–C037, C046","Missing evidence or next action":"Final detailed 2026 federal instructions not verified."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Insolvency","researcher_record":{"Assigned area / subtopic":"A067 — Insolvency","Status":"Answered","Findings / claims":"C035","Missing evidence or next action":"Complex contingent liabilities/assets may require case law."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Bankruptcy exclusion","researcher_record":{"Assigned area / subtopic":"A067 — Bankruptcy exclusion","Status":"Answered","Findings / claims":"C034, C047","Missing evidence or next action":"Individual bankruptcy facts remain case-specific."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Tax attributes","researcher_record":{"Assigned area / subtopic":"A067 — Tax attributes","Status":"Answered","Findings / claims":"C037, C047","Missing evidence or next action":"Specialized attribute/basis elections can be expanded."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Principal-residence debt","researcher_record":{"Assigned area / subtopic":"A067 — Principal-residence debt","Status":"Answered federally; CA mismatch addressed","Findings / claims":"C038, C045–C046","Missing evidence or next action":"2026 final CA instructions pending verification."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Farm debt","researcher_record":{"Assigned area / subtopic":"A067 — Farm debt","Status":"Answered","Findings / claims":"C050","Missing evidence or next action":"Specialized agricultural entities may need additional rules."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Real-property business debt","researcher_record":{"Assigned area / subtopic":"A067 — Real-property business debt","Status":"Answered materially","Findings / claims":"C051","Missing evidence or next action":"Detailed basis-election mechanics can be expanded."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Student loans/current-year transition","researcher_record":{"Assigned area / subtopic":"A067 — Student loans/current-year transition","Status":"Answered federally","Findings / claims":"C039","Missing evidence or next action":"State treatment must be checked separately."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Joint debt","researcher_record":{"Assigned area / subtopic":"A067 — Joint debt","Status":"Answered materially","Findings / claims":"C040","Missing evidence or next action":"Community-property/joint-return permutations deserve state-specific expansion."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Partnership/S corporation/business debt","researcher_record":{"Assigned area / subtopic":"A067 — Partnership/S corporation/business debt","Status":"Answered materially","Findings / claims":"C041–C042, C050–C051","Missing evidence or next action":"C-corp, guarantor, related-party and complex debt-modification rules can be deeper standalone modules."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Foreclosure/repo","researcher_record":{"Assigned area / subtopic":"A067 — Foreclosure/repo","Status":"Answered materially","Findings / claims":"C043–C044","Missing evidence or next action":"Property character, §121, depreciation recapture and state law remain separate layers."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Federal tax-debt compromise itself","researcher_record":{"Assigned area / subtopic":"A067 — Federal tax-debt compromise itself","Status":"Unresolved","Findings / claims":"C048","Missing evidence or next action":"Need direct published authority before saying accepted IRS OIC remainder is or is not COD."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — State cancellation taxation","researcher_record":{"Assigned area / subtopic":"A067 — State cancellation taxation","Status":"Answered for California 2025 final guidance; partial for 2026/all states","Findings / claims":"C045–C046","Missing evidence or next action":"Refresh California when final 2026 instructions issue; state-by-state conformity survey required."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."},{"topic":"A067 — Credit consequences","researcher_record":{"Assigned area / subtopic":"A067 — Credit consequences","Status":"Unresolved intentionally","Findings / claims":"Publication hold","Missing evidence or next action":"Form 1099-C tax reporting does not establish universal credit-reporting outcome."},"coordinator_acceptance":"not_accepted_remaining_detailed_review","coordinator_review_note":"Selected program/fee/statute checks only; see [internal evidence reference]. No50state/local tax or transaction certification."}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}