2026 UPDATE: All guides now verified for OBBBA Compliance and 2026 IRS Local Standards.

Authority Glossary

Tax Relief Glossary

Plain-English definitions of the terms that drive every IRS resolution decision. Each entry includes the law, the logic, and the 2026 update.

20 terms definedUpdated April 2026Source Registry

Settlement & Resolution

RCP (Reasonable Collection Potential)

Reasonable Collection Potential is the mathematical floor the IRS uses to evaluate an Offer in Compromise — the total amount the government believes it can collect from a taxpayer before the Collection Statute expires.

IRC § 7122IRM 5.15.1

Offer in Compromise (OIC)

An Offer in Compromise is a formal agreement between a taxpayer and the IRS to settle a tax debt for less than the full amount owed, accepted when collection in full would create economic hardship or the amount offered represents the most the IRS can reasonably expect to collect.

IRC § 7122IRM 5.8.1

Quick Sale Value (QSV)

Quick Sale Value is the IRS's estimate of what an asset would realistically sell for in a forced or expedited sale, typically calculated as 80% of Fair Market Value for most assets.

IRM 5.15.1

Installment Agreement (IA)

An installment agreement is a formal payment plan with the IRS that allows a taxpayer to pay a tax debt in monthly installments over a period of time rather than in a single lump sum.

IRC § 6159

Penalty Abatement

Penalty abatement is the reduction or elimination of IRS penalties assessed on a tax account, available through First-Time Penalty Abatement, Reasonable Cause, or Statutory Exceptions.

IRM 20.1.1

Fresh Start Initiative

The IRS Fresh Start Initiative is a set of administrative programs — expanded in 2011 and updated through 2026 — that may streamline access to installment agreements, lien relief, and Offer in Compromise settlements for taxpayers meeting certain criteria.

Collection & Enforcement

2026 Legislation

Business Tax

Financial Standards

Defense & Appeals

CDP Hearing (Collection Due Process)

A Collection Due Process hearing is a formal taxpayer right under IRC § 6330 to appeal an IRS lien filing or proposed levy before an independent Appeals Officer, with the option to escalate to U.S. Tax Court if Appeals disagrees.

IRC § 6330

CAP Hearing (Collection Appeals Program)

A Collection Appeals Program hearing is a faster, less formal IRS appeals process for disputing rejected installment agreements, proposed lien filings, or levies — but unlike a CDP hearing, it does not provide Tax Court access.

IRM 8.23.1

Audit Reconsideration

Audit reconsideration is an IRS administrative process that allows a taxpayer to dispute an assessment made from an audit they did not attend, did not agree with, or have new documentation to support.

Taxpayer Advocate Service (TAS)

The Taxpayer Advocate Service is an independent organization within the IRS that helps taxpayers resolve problems with the IRS and recommends systemic changes to prevent future problems.

Notice of Deficiency (90-Day Letter)

A Notice of Deficiency is a formal IRS determination that additional tax is owed, triggering a 90-day window during which the taxpayer may petition the U.S. Tax Court without first paying the disputed amount.

IRC § 6212

Innocent Spouse Relief

Innocent Spouse Relief is an IRS provision that releases one spouse from joint and several liability for tax, penalties, and interest when the other spouse improperly reported or omitted income on a jointly filed return.

IRC § 6015

All Terms A–Z