court erred in dismissing his petition because of a settlement agreement that he asserted existed between the parties, “[t]he Secretary may compromise any civil or criminal case arising under the internal revenue laws prior to reference to the Department of Justice for prosecution and defense.” 26 U.S.C. § 7122(a). The only three possible grounds for a compromise of federal tax liabilities are: (1) doubt as to liability; (2) doubt as to collectibility; and (3) the promotion of effective tax administration. Treas. Reg. § 301.7122-l(b). “An offer to compromise has not been accepted until the IRS issues a written notification of acceptance to the taxpayer or the taxpayer’s representative.” Treas. Reg. § 301.7122 — 1(e)(1); see also Klein v. C.I.R., 899 F.2d 1149, 1152-53 (11th Cir. 1990) (<HOLDING>). The requirements in §§ 7121 and 7122, and the
holding that the tax was indirect even though the recipient could not shift the tax to others holding that taxpayers failure to follow state requirement that he report change in federal income tax did not except state tax liability from discharge holding that the essential purpose of use tax is the recoupment of lost sales tax revenue holding that a binding settlement on a tax liability must follow the requirements of the tax code which include the execution of a closing agreement holding that operates as a charge of debtors in personam tax liability not debtors in rem tax liability