Step 4
Since a doubt as to liability is the result of either an assessment the IRS made because of an audit or because the IRS created a return for you because you did not file a return, an Audit Reconsideration or Offer in Compromise based on Doubt as to Liability may be appropriate resolutions.
Prepare and include original tax return(s) conspicuously labeled “OIC-Substitute For Return Reconsideration” (ONLY in the case where the IRS prepared substitute return(s) for the client).
Since the client believes that they can partially pay the IRS liability but there are exceptional circumstances that the IRS should consider for allowing them to pay less than their entire ability to pay (reasonable collection potential), an Offer in Compromise based on Doubt as to Collectibility with Special Circumstances may be an appropriate resolution.
Since the client believes they can full pay the IRS liability but there are exceptional circumstances that the IRS should consider for allowing them to pay less than the total liability, an Offer in Compromise based on Effective Tax Administration may be an appropriate resolution.
A preliminary assessment of your Reasonable Collection Potential (RCP) needs to be made to determine the most appropriate collection resolution.
Go to Resolution Evaluation