Offers in Compromise – Doubt as to Liability 656L – Former IRS Agents

October 26, 2010
Written by: steve

Fresh Start Tax is one of the industry leaders when its comes to Offers in Compromise. We are former IRS Agents who worked and taught the offer program while employed by the IRS. We have the highest rating given by the BBB.
General Information
An Offer in Compromise, 656L is a completely different offer in compromise than most of the other offers we hear about, see on television or advertised all over the place. These offers in compromise are based strictly as to the taxpayers position that the tax Liability is incorrect.
Definition of the Offer in Compromise 656 L
Doubt as to liability exists where there is a genuine dispute as to the existence or amount of the correct tax liability under the law. Doubt as to liability does not exist where the liability has been established by a final court decision or judgment concerning the existence or amount of the tax liability.

Grounds for compromise may exist when there is legitimate doubt from both the viewpoint of the taxpayer and the IRS. The taxpayer is required to submit documentation and/or other evidence to support his/her information for the OIC. The evidence available for both parties must be weighed in order to determine the extent of any “doubt. ”
What makes this Offer in Compromise Different
The taxpayer cannot be required to submit a financial statement for a doubt as to liability offer. Also, there is no application fee for a doubt as to liability offer.
Who works the offers in compromise, the 656L?
The Tax Examination Division has jurisdiction over DATL- OIC. Examination employees are responsible for preparation of the necessary documents and letters to effect the disposition of the DATL-OIC file by the taxpayer.
One exception
The Collection Division has jurisdiction of doubt as to liability offers involving the Trust Fund Recovery Penalty and Personal Liability for Excise Tax. Liability offers concerning assessments made during bankruptcy proceedings may also fall under the jurisdiction of the Collection Division.
One of the most important requirements about this offer in compromise is to make sure the offer is submitted with full documentation . The taxpayer should include copies of documents supporting their claim.

Filed Under: IRS Tax Advice
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