Sec. 5000.4. Record

Unless the unpaid amount of tax or other imposition which was the subject of the administrative action, including any interest, additions to the tax or penalty, is less than $50,000, if an offer in compromise is accepted, there shall be placed on file in the office of the commissioner the opinion of the counsel for the Department of Taxation and Finance with respect to such compromise, with the reasons therefor. The opinion shall include a statement of:

(a) the amount of tax or other imposition and any other issues which may be subject of such compromise;

(b) the amount of interest, additions to the tax, or penalties imposed on the taxpayer or other person against whom the administrative action was taken by the Department of Taxation and Finance; and

(c) the amount actually paid or required to be paid in accordance with the terms of the compromise.