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An offer in compromise (with doubt as to collectability) to the IRS should be equal to, or greater than what the IRS calculates as the taxpayer's reasonable collection potential.
But statistically, the odds of getting an IRS offer in compromise are pretty low. In fact, the IRS rejected 67% of all applications for offers in compromise in 2019. It's not impossible, though.
The taxpayer has a right to specify the particular tax liability to which the IRS will apply the 20 percent payment. Periodic Payment Offer - An offer is called a "periodic payment offer" under the tax law if it's payable in 6 or more monthly installments and within 24 months after the offer is accepted.
An OIC can be as advertised a fresh start from your IRS debt. No more looking over your shoulder with fear of an IRS seizure of your wages or bank accounts. Improved credit score after an offer in compromise is complete, the IRS will release all tax liens filed against you.
OIC Process Submitting an offer to the IRS is a formal process -- you can't simply call the IRS and say "Let's make a deal." You start by completing IRS Form 656, Offer in Compromise. There is a $186 application fee for filing an OIC, which you must attach to Form 656.