There are certain offers on cases that the IRS cannot accept. Though they are rare, here is a partial list of some of these types of cases:
They usually involve cases that are controlled by the Department of Justice.
The taxpayer’s liability for part or all of the periods are in litigation.
The federal liability for all or part that the taxpayer owes has been reduced to a federal judgment.
The offer received by the IRS is for tax periods that cover restitution that was court ordered. The IRS cannot modify the terms of any court order whatsoever.
The IRS has a civil or criminal prosecution pending against the taxpayer and those cases are already with the Department of Justice or the U.S. Attorney’s office.
The case was closed by Criminal Investigation and there is an indicator on that specific account that restitution was ordered. Counsel office must approve any action.
The offer is returned based on the collection division review.
Any case that has been high profile, in the newspapers and have public appeal are usually turned down by IRS due to public opinion of the agency, and rightly so.