As the regulation requires the IRS to consider alternatives for collection and not alternatives to collection, agency need not have resolved a compromise offer before an Article III court can permit the sale of the primary residence.
http://media.ca8.uscourts.gov/opndir/18/08/172825P.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.