There is a real point of disagreement about the existence of a liability or its amount. There is no question of liability when a final judicial decision has been rendered. This database is not common because you usually have several ways to convince the IRS that you don`t owe the tax. If you have not been able to convince the IRS that the adhesion is incorrect, something new should normally be available. The amount of the offer must reasonably reflect the amount the IRS intends to withdraw through litigation, including a risk assessment or litigation (at the sole discretion of the IRS). There is a separate form 656-L. Doubts about liability offers can no longer be submitted simultaneously to request a review on another basis. (k) the effective date. This section applies to compromise offers having served on or before July 18, 2002 or after July 18, 2002.

Section 6331 (k) (1) generally prohibits the IRS from imposing a tax on a subject`s property or property rights, while an offer to challenge liability is pending with the service for 30 days after a compromise offer is rejected or an appeal of refusal is pending. The statute of limitations for forfeiture is suspended, while the levy is prohibited. A compromise offer is pending when it is adopted for treatment. The service accepts a compromise offer for processing when it finds that: the offer is presented on the correct version of Form 656 and Form 433-A or B; The taxpayer does not go bankrupt; The subject met all of the reporting and payment requirements in the Form 656 instructions; The subject has attached the deposit tax, if necessary; and the offer meets all other minimum service requirements. The finding that the offer meets these minimum requirements means that the offer is changeable. Yourself (for example. B employment taxes) and other commitments with another person (for example. B Income Taxes), but you are the only one to make an offer, list all tax liabilities on 1 Form 656 and pay an application fee of $205 (or, if applicable, Form 656-A) and a 20% down payment or first payment. (1) Doubts about liability. There are doubts as to liability in the event of a genuine dispute over the existence or amount of the correct tax debt under the law. There is no doubt as to liability whether liability was established by a final judicial decision or by a judgment on the existence or amount of liability.