With no explanation, chose the best option from "A", "B", "C" or "D". 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

A: holding that the tax was indirect even though the recipient could not shift the tax to others
B: holding that taxpayers failure to follow state requirement that he report change in federal income tax did not except state tax liability from discharge
C: holding that the essential purpose of use tax is the recoupment of lost sales tax revenue
D: 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
D.