Los Angeles, CA: The Holy Grail of Tax Settlement Part 4 – OIC DATL

By
Services for Real Estate Pros with Howard Richardson
https://activerain.com/droplet/5pNS

An Offer in Compromise Doubt as to Liability (OIC DATL) is filed by a taxpayer that does not agree to some or all of the amount of a tax assessed by the IRS. 

This is in contrast to an Offer in Compromise Doubt as to Collectibility (OIC DATC) that I wrote about in a previous post where the tax assessment is accepted as accurate by the taxpayer who does not have the financial means to pay the tax debt in full.

 

Benefits of an Offer in Compromise Doubt as to Liability (OIC DATL) include:

1. If an OIC DATL is accepted, it can wipe out part or the total tax liability.

2. Stops collection enforcement (bank levies, wage garnishments, etc.) during the offer review. 

3. Taxpayer does not have to disclose financial information because they are asserting that they do not owe part or all of the tax.

4. Do not have to calculate Reasonable Collection Potential (RCP) as opposed to an Offer in Compromise Doubt as to Collectibility (OIC DATC).

5. Can offer only $1 to settle the debt or the partial amount of debt the taxpayer thinks they owe.

 

If there has been a court decision related to the tax assessment an Offer in Compromise Doubt as to Liability (OIC DATL) should not be filed because it will be rejected by the Offer Examiner.

There are multiple situations that warrant the filing of an Offer in Compromise Doubt as to Liability (OIC DATL):

1. Disputing the Trust Fund Recovery Penalty (TFRP) assessed against a responsible party which I discussed in a post about payroll taxes

2. New information is available to present that was not included in a previously closed audit or CP2000 (regarding an automated underreporter notice).

3. The auditor made a mistake interpreting tax law.

4. The auditor failed to consider evidence you presented.

 

If you fall into any one of these four categories and want to dispute a tax assessment that you do not think you owe, consider submitting an Offer in Compromise Doubt as to Liability (OIC DATL).

 

Howard Richardson

IRS and State Tax Representation

8939 S. Sepulveda Blvd., Ste. 102

Los Angeles, CA 90045

(323) 374-5034

howard@hrichtax.com

www.hrichtax.com

 

  

 

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