Form 656-L Guide: Resolve 'Doubt as to Liability' Issues 2025

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Doubt as to liability exists where there is a genuine dispute as to the existence or amount of the correct tax debt under the law. These offers are different from Doubt as to Collectibility since they are not based on the ability to pay the outstanding liability.
You suggest the amount to pay, and the IRS then can accept or reject your offer. To qualify for an OIC, you must be current with tax filings, not be in bankruptcy, have received a bill for at least one tax debt included on your offer, and make all required estimated tax payments for the current year.
Taxpayer Advocate Service (TAS) - This free service helps you resolve tax problems. Get help with delayed or undelivered refunds, assistance if you are unable to pay your taxes, and more. Find a local taxpayer advocate in your area. Low-Income Taxpayer Clinics (LITCs) - LITCs represent people in disputes with the IRS.
Do I qualify for the low income certification? You qualify if your adjusted gross income (AGI), as determined by your most recently filed income tax return (Form 1040 or 1040-SR), is less than or equal to the amount shown in the chart on Form 656, Section 1, based on your family size and where you live.
People often complain that they should not file an Offer in Compromise for a client because the acceptance rate is only 36%.
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Figuring out the optimal amount to offer the IRS is not easy. It takes a lot of experience to know where the sweet spot lies for any given case. In general though, you can start off with an estimate of 1 year worth of your disposable income and add to that any valuable assets you can sell for additional cash.
A doubt as to collectibility offer, is when you agree that you owe the taxes, but you cannot pay your tax debt in full. To be considered for a doubt as to collectibility offer you must make an appropriate offer based on what the IRS considers your true ability to pay.

offer in compromise form 656