If there is genuine disagreement or dispute regarding the amount or actual existence of a tax liability then Doubt as to liability exists. There are circumstances, however where there is no doubt according to the law (such as a court decision or judgement establishing a tax liability).
Doubt as to Liability is determined by an examination and evaluation of the evidence and circumstances of a taxpayer. To establish this doubt the taxpayer is required to submit documentation or evidence that will support his/her request for an Offer in Compromise agreement under a Doubt as to Liability position.
The Offer In Compromise examination, where Doubt as to Liability is asserted, is conducted similar to an audit reconsideration. The Offer is considered, additional requests for information are forwarded to the taxpayer if necessary, and all concerns, positions, or points are addressed by the IRS representative are addressed and then documented in the Offer Workpapers.
If you would like help in preparing an Offer In Compromise asserting Doubt as to Liability, please fill out the Free evaluation.
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