Our firm recently had a case where a taxpayer owed over $1 million and made an offer of settlement to the Department of Justice for just under $100,000. because the federal tax lien had been reduced to judgment.

Here is the format that was followed:

The offer in compromise was sent to the Internal Revenue Service.

The Internal Revenue Service offer group made a recommendation to the DOJ or the Department of Justice.

At that point the offer in compromise goes to reviewer from the DOJ who does not have settlement authority.

The reviewer specialist formats the case and sends it to a supervisor who goes ahead and makes a determination on the case.

You will find that the Department of Justice are not used to getting these offers in compromise from Internal Revenue Service.

We have found that there is no incentive for the Department of Justice really to accept it because the money goes to the Internal Revenue Service.

While we found the people friendly and willing to work is critical you talk to the person making the determination on the case.

This is a sales job!

You will find however that their settlements are not particularly based on the IRS settlement standards.

If you’re used to dealing with IRS on offer in compromise you will find there are no real standards.

It is up to the sole desecration of individual at DOJ .

On  our case they wanted a collateral agreement with the payment offered.

We are still in process of settlement.

I would not expect any consistency in dealing with DOJ in offers in compromise cases, however we did see a willingness to settle.