The Commissioner of Revenue Services or his authorized agent may compromise any controversy arising from the application or enforcement of any general statute over which said commissioner has authority. An offer of compromise may be made or entertained if it is based upon doubt as to the taxpayer's liability for the amount in controversy, or doubt as to the collectibility of such amount.
Conn. Gen. Stat. § 12-2d
( P.A. 96-221, S. 11, 25.)