OIC 113: Form 656, Offer in Compromise

Overview
Curriculum
Instructor

Instructor: Attorney Bob Schaller
Lectures: 5
Quizzes: 1

Form 656, Offer in Compromise.

An Offer in Compromise is an agreement between a taxpayer and the IRS that settles a tax liability for payment of less than the full amount owed. IRM § 5.8.1.2.1 (09-23-2008); Adamowicz v. US, 08-888C, Pg. 5 (D.C. Ct. Fed. Cl. 11/21/2011) (Offer in Compromise) and 26 U.S.C. § 7121 (closing agreements) and their regulations comprise the exclusive framework for the IRS and taxpayers to settle tax liability. Benson v. US, 120 F.3d 270, 270 (10^th Cir. 1993); Adamowicz v. US, 08-888C, Pg. 4 (D.C. Ct. Fed. Cl. 11/21/2011); see also Botany Worsted Mills v. US, 278 U.S. 282, 288-89 (1929) (“We think that Congress intended … to prescribe the exclusive method by which tax cases could be compromised.”). An Offer in Compromise is a way for the IRS to recoup a portion of the monies owed by a taxpayer unable to pay the back-taxes in full. IRM § 5.8.4.1.1 (01-18-2018).

Attorney Bob Schaller

Bankruptcy/Tax Attorney & Registered CPA

Bob has practiced law for more than 35 years and filed more than 3,000 bankruptcy cases. He has argued bankruptcy cases before the U.S. Court of Appeals, U.S. District Court, and U.S. Bankruptcy Court. He has authored 22 books including the 6-volume "Bankruptcy MasterClass Practice System & Toolkit."