 An Offer allows taxpayers to settle their taxes for less, OFTEN MUCH LESS, than they owe. Recent tax legislation has given new hope to taxpayers who were disqualified by the old Offer in Compromise procedures. The IRS Offer in Compromise (OIC) program was established by the U.S. Congress to help taxpayers who have experienced significant financial problems to get a fresh start, if they qualify. The Offer provides taxpayers who owe the IRS more than they could ever afford to pay, the opportunity to pay a small amount as A Full and Final Payment.
Marini& Associates, PA has extensive expertise with planning, preparing, negotiating and even appealing rejections of IRS Offer. Since 1992 we saved MILLIONS OF DOLLARS for our clients through the Offer in Compromise program.
We get our edge by knowing and carefully navigating virtually every key regulation of the Offer in Compromise program. Our tax attorneys also have a good working relationship with many of the IRS Offer in Compromise Specialists working for the IRS and State taxing agencies.
 Internal Revenue Code authorizes the IRS, to accept less than full amount of tax liability owed in any civil or criminal case arising under the tax laws prior to the case's referral to the Department of Justice. For an Offer in Compromise to be accepted, the taxpayer must establish to the satisfaction of the IRS that the taxpayer either: has no means of paying the tax or does not actually owe the tax.
The IRS will accept an Offer in Compromise when it is unlikely that the tax liability can be collected in full and the amount of the Offer in Compromise reasonably reflects collection potential. An Offer in Compromise is a legitimate alternative to declaring a case as currently not collectible, or to a protracted installment agreement. The goal is to achieve collection of what is potentially collectible at the earliest possible time and at the least cost to the government.
An IRS Offer in Compromise Is Not An Amnesty Program
The IRS has the authority to settle or compromise federal tax liabilities by accepting less than full amount under certain circumstances.
One of the following factors must be established in order for the IRS to accept an Offer in Compromise and settle the liability:
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