Qualified Offers to Resolve Tax Disputes: New Case Shows How “Settling” Could Cost Taxpayers

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Qualified Offers to Resolve Tax Disputes: New Case Shows How “Settling” Could Cost Taxpayers

January 27, 2026

Journal of Taxation

One of the most powerful tools for taxpayers entangled in tax disputes is the “Qualified Offer.”  It can lead to early resolution of cases on favorable terms, fee recoupment, or both.  Unfortunately, many taxpayers and their advisors are unaware of this strategic instrument, or they are aware of it but fail to employ it properly.  This article by Partner Hale Sheppard explores the normal method for recovering administrative and litigation fees from the government, unique aspects of Qualified Offers, and the newest case, Greenwald v. United States, in which a Qualified Offer takes center stage.

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halesheppard@eversheds-sutherland

Hale E. Sheppard

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Atlanta, United States

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