The amount of any penalty or assessment which has become final, or for which a judgment has been entered under § 16.42 or § 16.43 , or any amount agreed upon in a compromise or settlement under § 16.46 , may be collected by administrative offset under 31 U.S.C. 3716 , except that an administrative offset may not be made under this subsection against a refund of an overpayment of Federal taxes, then or later owing by the United States to the defendant.
31 C.F.R. §16.44