TC 482: Offer in Compromise Withdrawn or Terminated

What the code actually does

TC 482 records the withdrawal or termination of a pending Offer in Compromise. A withdrawal is voluntary when the taxpayer pulls the offer back and involuntary when the taxpayer misses a required TIPRA payment (the payment the Tax Increase Prevention and Reconciliation Act of 2005 requires while an offer is pending) and the IRS closes the offer, as IRM 5.8.7.1.6, Terms/Definitions/Acronyms defines it; if the IRS erred, for instance by not posting a payment it received in time, it can reopen the offer with a new TC 480 date per IRM 5.8.7.4.2.1, Reopening an Involuntary Withdrawal (IRS Error). A termination is narrower still: per IRM 5.8.7.1.6, it means specifically that the taxpayer died during the offer’s pendency, not any IRS-initiated closure for cause — a closure over a missed condition or noncompliance is a return instead, which closes under TC 481, not TC 482. Like TC 481, TC 482 ends the TC 480 pending status and extends both statute clocks that paused while the offer was active: the ASED (Assessment Statute Expiration Date — the deadline for the IRS to bill more) and the CSED (Collection Statute Expiration Date — the deadline to collect what is already billed).

The ASED extension

IRM 5.8.10.8(5) states the general rule covering all four offer outcomes together: "For an offer that has been rejected, returned (processable), terminated or withdrawn, the amount of any federal tax due for a tax period included on the offer may be assessed on the latest allowable assessment date plus the period of time the offer is pending, plus one year." The Form 656 (Rev. March 2011 or later) table backs this with a dedicated TC 482 row, parallel to and worded the same way as the TC 481 row: the ASED extends from the TC 480 date to the TC 482 date, plus one additional year.

Under an older, superseded Form 656 table (May 2001–March 2009), a withdrawn offer got only the base pendency period without the extra year — but that version does not govern current offers, and should not be applied to one by habit or by pulling an old reference.

The CSED extension — a real asymmetry worth naming

IRM 5.8.10.7, the collection-statute chart, is written entirely in terms of a rejected offer (TC 481) and contains no row naming TC 482 specifically. That does not mean a withdrawn or terminated offer leaves the CSED untouched: the suspension runs from the TC 480 date to the TC 482 date (IRM 5.1.19.3.4.1). The extra 30 days that follow a rejected offer (TC 481) do not apply to a withdrawal or termination. Recompute the CSED from the actual TC 480 and TC 482 dates.

The practitioner’s actual next step

Apply the same one-year ASED extension to a TC 482 that you would to a TC 481 — current IRM text and the Form 656 table both confirm this directly, so there is no reason to treat a withdrawn offer as carrying a lighter statute consequence.

Recompute the CSED from the TC 480 and TC 482 dates, with no added 30 days, using The Federal Tax Desk’s CSED Calculator rather than estimating.

On a business account, the same trust-fund-recovery-penalty carve-out that applies to TC 481 applies here — the underlying business assessment statute extends, but the separate TFRP assessment statute against a responsible individual does not.

If recomputing the CSED or ASED surfaces a prior miscalculation on an existing or former client’s file, treat it as a potential claim circumstance, not just a data correction; policies differ on when notice is due, so confirm the specific notice trigger in the practitioner’s own professional liability policy.

What people mistake TC 482 for

TC 482 and TC 481 have the same effect on the assessment statute; on the collection statute the suspension runs from the TC 480 date to the TC 481 or TC 482 date. The IRS already builds a rejection’s 30 days into the TC 481 date. Where it is worth being precise is explaining to a client why an offer ended: a rejection or return (481) is the IRS declining or closing the offer on procedural or merits grounds; a withdrawal (482) means the taxpayer — or, in an involuntary withdrawal, the IRS itself — pulled the offer back; a termination (482) is narrower still, tied specifically to the taxpayer’s death during the offer’s pendency. Those are different conversations about what happened, even though the assessment-statute math converges. Whichever of these closed the offer, the IRS still gets the same extra year to assess. Appeal rights don’t follow the same symmetry: a rejection carries an explicit 30-day path to the IRS Independent Office of Appeals; a taxpayer who receives an involuntary-withdrawal letter can telephone to object to the closing; and a termination, following the taxpayer’s death, raises a different question this page does not resolve — who besides the taxpayer, such as an estate or executor, may have standing to contest the closure.