Andrew Filipowski v. Commissioner of Internal Revenue

Summary

The court affirmed the Tax Court’s grant of summary judgment upholding the IRS’s rejection of Filipowski’s offer in compromise on public-policy grounds. Although Filipowski identified factual disputes concerning his assets, reporting history, and ability to pay, the court held that the undisputed facts independently supported the IRS’s discretionary determination that accepting the offer could diminish public compliance with the tax laws.