How IRS Processes the Offer on Compromise, Former IRS Agent, Michael D. Sullivan


Being a former IRS agent and teaching instructor of the offer in compromise there are so many myths about the program it’s hard to keep up with. Don’t shoot me I am  just a messenger.

When I worked at Internal Revenue Service there were few offers in compromise filed and then due to all the advertising the Internet and social media the offer in compromise program of the Internal Revenue Service has swelled into a beast and many taxpayers have the completely wrong idea about the offer in compromise program. if everyone could settle their debt with the Internal Revenue Service there would be lines around the United States to get in government buildings to settle their tax debt however there are strict standards for IRS settlements and if it was so easy it would compromise and cripple the economy of the United States. There is a very specific program for taxpayers to get their tax debt forgiven by the Internal Revenue Service. Below you will find some of the concerns the myths and tips in filing an offer in compromise.


The majority of calls that I get or from taxpayers that believe that IRS is going to settle their tax debt because of the ads they see on TV the Internet and various marketing techniques.

While the offer in compromise is a true program offered by the Internal Revenue Service, approximately 32,000 Americans get their offers in compromise approved by Internal Revenue Service because they are true qualified candidates for the program.The majority do not get accepted.

The average settlement is $6500 per case in approximately 32% of all offers in compromise are accepted by the Internal Revenue Service.

Unfortunately there are many IRS debt settlement companies that take cases, make promises and their clients offer have no chance of going through the IRS system to settle their tax debt.

Many of these companies charge thousands of dollars and I hear all the stories as people call me after other companies have failed to perform. I warn any taxpayer who wants to hire a company to speak to the person who will be working their case before giving their money to any IRS debt settlement company. You should find out how many offers they have worked and get a gut feeling about what you think their level of expertise is. I would also suggest that you speak to somebody who’s worked for the Internal Revenue Service and knows the program inside and out.

Everybody should know that the Internal Revenue Service has an offer and compromise pre-qualifier tool and if they do not call a professional company they should walk through the pre-qualifier tool on

So how does the offer in compromise get process through the Internal Revenue Service.

First of all, a reviewer looks at the offer to make sure the offer can be referred to a revenue officer. The offer in compromise must from a technical standpoint be filled out completely have all signatures and all key elements of the 656 in place.

The reviewer then pulls up a transcript to make sure all the tax returns have been filed. If the offer in compromise is not filled out correctly all tax returns not filed, the reviewer sends it back to the taxpayer.

Once it passes the test of the reviewer, the offer is then passed on to a revenue officer specialist who has been trained by the Internal Revenue Service what to look for and what can be accepted by the Department of treasury.



The offer in compromise is a binding contract or covenant between the Department of treasury and the taxpayer and is a true legal settlement and document.

Once the revenue officer who is the offer in compromise specialist looks at the financial statement that person will get a general sense of how they feel about the offer in compromise.



Put a letter or an accompaniment document letting the reviewer know from the beginning why your client or taxpayer needs to have this offer accepted and any extenuating circumstances that may exist.




It puts a idea in the mind of the revenue officer of the desperate situation that the taxpayer is going through. The reason this is important is that the revenue officer is only looking at a piece of paper is removed from the reality of the taxpayer.

The job of a true practitioner is to help your client.

So you must make the situation real to the Internal Revenue Service as to understand the effects of the burden of the tax liability.

As a former IRS agent revenue officer I would look at the offer, glanced through, it look at the numbers, look at the written statement and kinda have a feeling about the offer in compromise. It is very important for that initial review to ge well, the IRS offer specialist feel good about working the offer in compromise, it sets the tone.

Please keep in mind it is much easier for a revenue officer offer in compromise specialist to reject the offer in compromise because there is a lot of process work and due diligence that a person must do to accept the offer in compromise.

Not only do you as a revenue officer have to approve the offer but so does your manager, the regional manager and so does the district council of Internal Revenue Service for legal purposes.

Many people ask why this process is so extensive and why so much time is spent.

The answer is quite simple, all offers in compromise that are accepted by the Internal Revenue Service are open to public review for one year at certain regional tax offices so the public can review offers in compromise and see which cases IRS accepts and which cases they do not.

So you can expect the Internal Revenue Service to be very cautious and more importantly use the same standard to accept every single offer in compromise. Appearance is very important to the Internal Revenue Service

Once the revenue officer starts looking at the financial statement they pay a lot of time to three main things:

1.the assets,

2.the income, and,

3.the expenses claimed by the taxpayer.



The revenue officer wants to make sure that they’re getting their full liquidated value as part of the basis for settlement to Internal Revenue Service.

IRS will discount your residence approximately 20% but IRS generally will never settle for less than full liquidation value of the assets of any taxpayer and/or business.

Also keep in mind assets includes IRAs, pensions, stocks, and values of businesses that the taxpayer may own.

Next the revenue officer will move on to the expenses claimed against income.

The revenue officer will compare the national, regional, and geographical standards of the cost-of-living are in every region of the United States and compare that to the income.

The IRS’s job is to make sure that the taxpayer is living well within their means before they will accept an offer in compromise.

The goal of the Internal Revenue Service is to make sure the taxpayer has to borrow money from third-party to pay the offer in compromise and to settle their tax debt. Any money in possession of the taxpayer in any savings account or checking account generally must be included in the offer in compromise.

( please keep in mind that exceptions exist in certain cases.)

Once the revenue officer is pretty certain that this is a doable or acceptable offer, it puts the offer through a series of financial tests to make sure the documentation on the financial statement is correct.

The IRS agent will spend approximately 20 to 40 hours to work an offer in compromise.

The Agent will do Google searches to check businesses and an individual’s name to find out if there are assets, it will use the accurate search engine to look for back assets, it will pull DMV records, pull courthouse records, and will use other search engines to make sure that this offer can be acceptable by the Internal Revenue Service.’s

One of the great sources that IRS can use is a credit report.

There is a plethora of information on a credit report and on large cases the revenue officer can and will pull a credit report up.

After the revenue officer is convinced this is a doable offer they will package up the case and send it to the manager for review and acceptance .



A taxpayer can file as many offers in compromise as they wish. Many times if an offer in compromise is rejected the first time the taxpayer should find out why the offer was rejected fix the errors or problems and resubmit the offer in compromise after a period of time when the problems and issues from the first offer have been resolved. learn your lessons from the first rejection and make them successful the second time around.


What to Do if the Offer is not accepted.


Keep fighting, do not give up!

In almost all cases we send an appeal and to get it to a third-party who is not connected with the collection division.

We love the sending cases to and appellate officer who was a better and more balanced person to accept the offer in compromise.

If you have any question about your case or like us to review your offer in compromise or process it call us today for a free initial tax consultation.

You will hear the truth about the offer in compromise.

Call me today for a free initial tax consultation I will walk you through the program of the offer in compromise.

How IRS Works The Offer in Compromise + Michael D. Sullivan, Former IRS Revenue Officer, Free Consult

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Mr. Michael D. Sullivan

Michael D. Sullivan is the founder of MD Sullivan Tax Group. He had a distinguished career with the Internal Revenue Service for 10 years. As a veteran IRS Revenue Officer / Agent, he served as an Offer in Compromise Tax Specialist and Large Dollar Case Specialist.

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