Offers in Compromise Strategies: Using OICs to Challenge Assessments and Request Reconsideration of Tax Bills
Filing Doubt-as-to-Liability Claims and Grounds for OICs Under Efficient Tax Administration Reasoning
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers and compliance professionals with a thorough and practical guide to navigating the IRS offer-in-compromise (OIC) procedures, detailing the three types of OIC submittals available to taxpayers. The panel will focus on using the OIC program to preserve taxpayer rights to challenge IRS assessments, and outline practical strategies for determining when to file an Offer in Compromise (Doubt as to Liability) (DATL). Participants will gain valuable tools for effectively representing taxpayers and negotiating with the IRS during the appeal process.
- Bases for OIC available to taxpayer
- OIC-Doubt as to Collectibility (DATC)
- OIC-Effective Tax Administration (ETA)
- OIC-Doubt as to Liability (DATL)
- DATL criteria
- DATL standards of review
- OIC strategies
- Filing and documentation requirements
The panel will discuss these and other important topics:
- In what types of tax disputes may a taxpayer use an OIC DATL to try to get reconsidered?
- Reporting mechanics for a DATL
- What are the standards for an OIC citing ETA as grounds for a compromise amount?
- IRS standard of review for DATL filings
Benjamin J. (Ben) Peeler, J.D., CPA, LL.M.
Mr. Peeler leads his firm's IRS Practices & Procedures team as a federal tax, controversy and procedure... | Read More
Mr. Peeler leads his firm's IRS Practices & Procedures team as a federal tax, controversy and procedure specialist. He works with clients in the controversy areas relating to income tax, estate and gift tax, property tax, employment tax and other various tax matters. He represents clients before the IRS in examination, appeals, collection, penalty abatement, audit reconsideration, interest abatement and interest netting. Previously, he worked as an attorney for the IRS Office of Chief Counsel, and also, led and instructed groups of attorneys, revenue agents and revenue officers through various procedures.Close
A.J. Gross, CPA, EA
President and Founder
ALG Tax Solutions
Mr. Gross helps individuals and businesses handle tax problems with the IRS or state. Since beginning his... | Read More
Mr. Gross helps individuals and businesses handle tax problems with the IRS or state. Since beginning his career in tax resolution, he has assisted hundreds of clients in resolving their tax issues. He works with his clients to solve complex financial problems and to customize workable tax solutions.Close
Howard S. Levy
Voorhees & Levy
Mr. Levy is a former IRS trial attorney with over 20 years of experience representing individuals and companies... | Read More
Mr. Levy is a former IRS trial attorney with over 20 years of experience representing individuals and companies facing tax controversies. His expertise includes finding solutions to IRS collection problems, with an emphasis on the use of bankruptcy.He is a regular contributor to journals and newspapers regarding the IRS.Close