On February 2, 2022, the Tax Court issued a Memorandum Opinion in the case of Estate of Washington v. Commissioner (T.C. Memo. 2022-4). The primary issue presented in Estate of Washington was whether offers-in-compromise presented by the estate qualified for effective tax administration consideration. No George and Martha Mr. Washington (Tony) wed Mrs. Washington (Lenda) in 1981. They had one child. They divorced in 2006. Mr. Washington had unpaid income tax liabilities for 2008, 2009, 2010, 2014, and 2015. Mr. Washington died in November of 2015. Ironically, the Washingtons lived in Washington, D.C. Three provisions of the marital settlement agreement (“MSA”) are particularly relevant to this case. They relate to (i) Mr. and Ms. Washington's retirement plans, (ii) a life insurance policy provided to Mr. Washington through his employer, and (iii) Mr. and Ms. Washington's intentions concerning the interaction of the MSA and the Divorce Decree. Both parties waived any…