An offer in compromise (OIC) is an agreement between a taxpayer and the Internal Revenue Service that settles the taxpayer’s tax liabilities for less than the full amount owed. Absent special circumstances, an offer will not be accepted if the IRS believes that the liability can be paid in full as a lump sum or through a payment agreement.
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Using Offer in Compromise services as an example, we have the advantage of having "offer in compromise" cases throughout the U.S. In negotiating offer in compromise settlements, we have a national perspective to prevent IRS error and misapplication of the tax law. We have unique insight into unpublished IRS administrative practices and policies in offer in compromise cases. For these reasons, we are able to settle offer in compromise cases at the lowest amount that the IRS will accept for an "acceptable Offer" (i.e., final settlement). In addition, our insight into IRS administrative practices in offer in compromise cases minimizes the opportunities the IRS has to return an Offer case without resolution. We prepare offer in compromise Form 656 and financial statement Form 433A and Form 433B so that the presentation to the IRS is professional. A tax attorney prepares a legal memorandum in all Offer in Compromise filings, in order to make sure that the IRS is following the IRS statute on §7122 (the OIC statute), the Offer regulations, the legislative history, the tax policy in Offer cases, the Offer case law, and the Revenue Procedure in offer in compromise cases. The task of our tax lawyers in offer in compromise cases is to force the IRS to follow the all of the legal and administrative procedures as well as the Congressional mandate to the IRS to be "liberal" in OIC cases.
