656 for the tax years 1986 through 1993. The IRS acknowledged Debtor's offer on November 17, 1994. One hundred sixty-nine (169) days elapsed between the IRS's May 30, 1994 assessment of Debtor's 1993 taxes and its November 17, 1994 acknowledgment of Debtor's offer in compromise concerning 1993 tax liabilities.
Debtor submitted an amended offer in compromise concerning tax years 1986 through 1994 on May 10, 1995, which offer was acknowledged on May 19, 1995. By letter dated June 22, 1995, the IRS notified Debtor that the May 19, 1995 offer was rejected, but that Debtor had a right to protest the IRS's determination and request a conference. By letter dated July 18, 1995, Debtor submitted a protest and requested a conference. Subsequently, by letter dated May 14, 1997, the71 (1978), U.S.Code Congressional & Administrative News 1978, p. 5857.
The Government contends that the quoted comment was for illustrative purposes only and should not be interpreted as the exclusive factual scenario to which Congress intended the tolling provision to apply. The Government, however, offers no *675 more than speculation and policy arguments to support this interpretation. These arguments are insufficient to overcome the plain language of the statute. Indeed, the absence of any discussion in the legislative history of tolling on account of pre-assessment offers in compromise counsels against the Government's broad interpretation of the statute.
Section 507(a)(8)(A)(ii) refers specifically to offers in compromise made after assessment and the cited legislative history specifically refers to offers in compromise made following an offer in compromise. Thus, the legislative history provides