In Part I, I describe the basic features of the OIC procedure and
explain its importance. I first describe the procedure as it currently
exists on paper. I then defend the need for a robust but tailored debtforgiveness
procedure by arguing that such a procedure (1) enables
the IRS to collect more revenue, (2) reflects a rich conception of distributive
justice that looks beyond assessed tax liabilities, and (3) comports
with the realities of a world in which debtors sometimes cannot
repay their debts. Such a system serves society’s interests in debtor
rehabilitation as well as social and economic stabilization.