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Posted on Sep 3, 2011 in Offer in Compromise | 0 comments

Offer in Compromise for Doubt as to Liability

Another type of offer in compromise is based on doubt as to liability.  This type of offer in compromise is very different from the one based on doubt as to collectability because you are telling the IRS you do not feel that you do not have to pay the taxes because you are not liable for the taxes.  This type of offer in compromise is unusual because when there is a chance that you are not liable for the taxes that the IRS claims you owe there are many other avenues to resolve those questions.

A “Doubt as to liability” exists where there is a genuine dispute as to the existence or amount of the tax liability. Grounds for compromise may exist when there is legitimate doubt from both the viewpoint of the taxpayer and the IRS. Validity of the DATL-OIC is determined by evaluating the supporting evidence and circumstances.It is the taxpayer’s job to submit documentation and other evidence to support his claim that the tax liability is not correct.