MA S2027

Authorizes the Commissioner of Revenue to enter into written settlement agreements with taxpayers to resolve tax liability disputes for any tax period ending before the agreement date

Permits compromises based on three grounds: doubt as to liability (genuine dispute over correct tax amount), doubt as to collectability (taxpayer assets/income less than amount owed), or to promote effective tax administration through equity considerations

Requires taxpayers to be current on all tax filing requirements before making a settlement offer, and may impose a 3-year compliance period requiring timely filing and payment of all future taxes

Establishes two payment options: lump-sum offers (5 or fewer installments with 10% upfront payment) or periodic payment offers (up to 36 installments with first installment due at submission)

Requires Attorney General review for any settlement that accepts $50,000 or more below the full amount owed, and mandates procedures for counteroffers, independent review of rejections, and taxpayer appeals