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Courses/Law/Tax Law

Alphabet Soup for Offers in Compromise

This presentation will cover the nuances of offers in compromise highlighting the issues that arise most frequently.

Created byMichael J. DeBlis III, Esq.
5.0
(3 reviews)
BeginnerUpdated Sep 3, 2025
Alphabet Soup for Offers in Compromise

What You'll Learn

check_circleAnalyze how the IRS determines a taxpayer's eligibility for an offer in compromise based on doubt as to collectability and the factors considered during evaluation.
check_circleUnderstand the concept of "reasonable collection potential" and its impact on a taxpayer’s ability to settle tax liabilities through an offer in compromise.
check_circleExamine the implications of collateral agreements in offers in compromise and how they may affect a taxpayer’s future income and ongoing relationship with the IRS.
check_circleEvaluate the circumstances under which the IRS may accept an offer in compromise for effective tax administration, even when the taxpayer has the means to pay in full.
check_circleDiscuss the procedural steps involved in appealing the rejection of an offer in compromise and how these steps may influence the likelihood of a successful appeal.
check_circleCompare the IRS’s approach to offers in compromise based on doubt as to liability versus doubt as to collectability, highlighting the reasons for the differences in evaluation.

About This Course

Taxpayers who have few assets and little prospect of generating sufficient income to pay a tax liability in full may be allowed to reach a settlement for less than the full amount to settle their case. This is known as an offer in compromise. The IRS's acceptance of an offer in compromise conclusively settles the liability, absent fraud or mistake. This presentation will cover the nuances of offers in compromise, highlighting the issues that arise most frequently.

Key topics covered include:

  • The three statutory grounds for compromise: Doubt as to Liability, Doubt as to Collectibility, and Effective Tax Administration.
  • Required forms (656 and 656-L), associated fees, and necessary down payments.
  • The IRS evaluation process, including calculating reasonable collection potential based on assets and future income.
  • Understanding the impact of OIC submission on IRS collection activities and the statute of limitations.
  • The procedures for OIC acceptance and the critical steps following rejection, including appeal rights and strict timelines.
  • Navigating the role of collateral agreements.

This course provides clear, actionable insights into the criteria, documentation, and strategies essential for successfully guiding taxpayers through the OIC landscape.

Your Instructor

Michael J. DeBlis III, Esq.
Michael J. DeBlis III, Esq.

Trial, entertainment law and U.S. international tax law

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star739 reviews

Michael is a partner in the boutique law firm of DeBlis Law where he specializes in tax compliance and entertainment law. Michael graduated from Western Michigan University School of Law in 2007 and later went on to earn his Masters of Law in taxation (LL.M.) from Thomas Jefferson School of Law in 2012. As a former public defender, Michael has spent nearly eight years cutting his teeth on some of the most serious felony cases to pass through the state courts of New Jersey. Michael’s unique background in tax law puts him into an elite category of criminal defense attorneys who specialize in criminal tax defense. His extensive trial experience and solid grounding in all major areas of federal taxation make him uniquely qualified to handle any white-collar case, no matter how sophisticated it might be. Michael is known for his creativity, his charismatic personality, and his unyielding dedication to his clients. As a graduate of the National Criminal Defense College, Michael has trained under some of the best known criminal defense attorneys in the country. That experience has taught him that justice for a person accused of a crime is only won through a full understanding of the client and the case. To that end, Michael attempts to understand each client’s case as a convincing narrative, not just as a set of innocuous facts and arcane legal rules. When he's not in the courtroom, you can find Michael on stage. As a professionally trained actor, Michael's passionate about helping trial lawyers harness the power of persuasion and positive communication in the courtroom in order to connect to the jury on a human level. Michael's training as an actor allows him to combine a unique blend of left-brain thinking with right brain artistry to make even the most dull and abstract areas of the law come to life. This burst of creativity has contributed to Michael's success as a distinguished author and sought-out speaker. Michael has written articles that have been published in leading tax journals, such as "CCH Journal of Tax Practice and Procedure," "EA Journal," "Global Tax Weekly," and "ABA News Quarterly" and is a columnist for "Law360." He has been featured on the media affiliates of several major media networks, including NBC, ABC, CBS, Fox, and CNN. Michael is a living example of the tremendous power that comes from combining passion, preparation, persuasion, and positive communication in the courtroom. His courage and relentless work ethic have earned him a reputation as a zealous advocate and one of New Jersey's rising stars of the legal profession.

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What Students Are Saying

5.0
Student's Choice
3 reviews

Frequently Asked Questions

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