(a) In all appropriate instances, a compromise that is accepted by NRC should be implemented by means of a mutual release.
(1) The debtor is released from further non-tax liability on the compromised debt in consideration of payment in full of the compromised amount.
(2) The Government and its officials, past and present, are released and discharged from any and all claims and causes of action arising from the same transaction held by the debtor.
(b) If a mutual release is not executed when a debt is compromised, unless prohibited by law, the debtor is still deemed to have waived any and all claims and causes of action against the Government and its officials related to the transaction giving rise to the compromised debt.
[67 FR 30322, May 6, 2002]