The IRS is likely to reject an OIC where a taxpayer has an egregious history of past noncompliance and the IRS's analysis of the taxpayer's current finances indicates that it will be highly unlikely the taxpayer will be able to remain in compliance during the offer period. The IRS is also likely to reject and OIC where the IRS's financial analysis of a taxpayer indicates that the taxpayer's business does not have the ability to fund the offer, remain current with its future tax obligations, and at the same time meet its normal operating expenses.
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