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

IRC § 7122 — Form 656

Offer in Compromise

A legal agreement to settle your entire IRS tax debt for less than the full amount owed. The IRS will accept it only when your ability to pay — your Reasonable Collection Potential — falls short of what you owe.

Form 656 + 433-A(OIC) 4–12 Month Review Period $205 Application Fee

What Is an Offer in Compromise?

An Offer in Compromise (OIC) is not a negotiation where you make a low offer and the IRS counters. It is a mathematical determination. The IRS will settle for less only when the math shows they cannot realistically collect the full amount before your collection statute expires. If the numbers support it, the IRS is required by policy to accept the lowest offer that reflects your Reasonable Collection Potential.

Three legal grounds for an OIC exist under IRC § 7122:

Most Common

Doubt as to Collectibility

You cannot pay the full liability before the 10-year collection statute (CSED) expires. This is by far the most common basis for OIC acceptance.

Disputed Tax

Doubt as to Liability

You dispute the correctness of the underlying tax assessment — not just the amount, but whether you actually owe it at all.

Hardship/Equity

Effective Tax Administration

You can technically pay, but collection would create severe economic hardship or be fundamentally unfair given exceptional circumstances.

The RCP Formula: How the IRS Calculates Your Minimum Offer

Reasonable Collection Potential (RCP) is the IRS formula that determines the absolute minimum offer they will accept. Your offer must equal or exceed your RCP. There are two components:

RCP = Quick Sale Value of Assets + Future Income

1Quick Sale Value (QSV)

The IRS values your assets at 80% of fair market value — the "quick sale" price if you had to sell immediately. This includes bank accounts (100%), retirement accounts (after applicable taxes and penalties), home equity, vehicles, and investments.

QSV = (Asset FMV × 0.80) − Secured Debt

2Future Income

Monthly Disposable Income (MDI) is your gross income minus IRS-allowed necessary living expenses (National and Local Standards). MDI is then multiplied by either 12 months (lump sum) or 24 months (periodic payment).

MDI = Gross Income − IRS Allowed Expenses
Future Income = MDI × 12 (or × 24)

OBBBA 2026: Overtime Deduction Reduces Your MDI

The One Big Beautiful Bill Act (effective 2025, P.L. 119-21) created an above-the-line deduction for qualified overtime pay. If you earn overtime, this deduction reduces your gross income before the IRS calculates your MDI — directly lowering your Future Income component and your minimum offer.
  • • Single filer: up to $12,500 overtime deduction (phases out above $150,000)
  • • Married filing jointly: up to $25,000 (phases out above $300,000)

Source: One Big Beautiful Bill Act, P.L. 119-21 § 101

Lump Sum vs. Periodic Payment: Which Should You Choose?

The payment method you choose affects both how much you must offer and what cash you need upfront. Neither is inherently better — it depends on your cash position.

FactorLump Sum OfferPeriodic Payment Offer
Future Income Multiplier12 months24 months
Initial Payment with Application20% of offer amountFirst installment payment
Remaining Balance After AcceptanceWithin 5 monthsContinuing monthly installments
Payments During IRS ReviewNone requiredMonthly installments continue
Lower Minimum Offer?Yes (12x multiplier)No (24x multiplier)
Best ForTaxpayers with cash or assets to fund 20%Taxpayers with low cash but steady income

Low-Income? Fee and Payment Waivers Available

If your income is at or below 250% of the federal poverty level, you qualify for the Low-Income Certification (Form 656-A). This waives the $205 application fee AND the 20% initial payment for lump sum offers — filing is free with no upfront cash required.

Eligibility: What You Must Have Before Filing

The IRS will return your offer — without reviewing it — if you do not meet these threshold requirements. Getting these right before you file is non-negotiable.

All required tax returns filed for all years
All required estimated tax payments made (if self-employed)
All required federal tax deposits made (if you have employees)
Not currently in an open bankruptcy proceeding
$205 application fee paid (or Low-Income Certification attached)
20% initial payment included (lump sum) or first installment (periodic)
Cannot be in an open bankruptcy — OIC and bankruptcy cannot coexist
Cannot have unfiled returns — the IRS will not process offers with missing returns

Form 656 and 433-A(OIC): What You Are Actually Filing

An OIC application is a package of documents. The IRS will not process it unless everything is included and complete. Here is what goes in the envelope:

Form 656

The Offer Application

The formal offer document. You state the dollar amount you are offering, the payment method (lump sum or periodic), and the legal basis (Doubt as to Collectibility, Doubt as to Liability, or Effective Tax Administration). You sign under penalties of perjury.

IRS.gov
Form 433-A(OIC)

Collection Information Statement (Individuals)

Your complete financial picture: income from all sources, monthly living expenses, assets (bank accounts, retirement, real estate, vehicles), and liabilities. Every number on this form feeds directly into the RCP calculation. Accuracy is critical — the IRS verifies through third-party data.

IRS.gov
Form 433-B(OIC)

Collection Information Statement (Businesses)

Required if you are a business owner or have business-related liabilities included in the offer. Covers business income, expenses, assets, and liabilities.

IRS.gov
Form 656-A

Low-Income Certification (if applicable)

Attach if your household income is at or below 250% of the federal poverty guideline. Waives the $205 application fee and initial payment requirement.

IRS.gov

What Happens After You Submit

1

Processability Review (4–6 weeks)

The IRS checks completeness. Are all returns filed? Is the application fee included? Is the initial payment attached? If anything is missing, the offer is returned unprocessed — not rejected. You can resubmit.

2

IRS Suspends Collection Activity

Once the offer is in processability, the IRS cannot levy your wages or bank accounts during the review period. However, the CSED (collection statute) is tolled — it stops running for the duration of the review plus 30 days.

3

Financial Verification (2–6 months)

An IRS offer examiner reviews your 433-A(OIC). They verify your numbers against IRS databases, W-2s, 1099s, and property records. They may request additional documentation. They recalculate your RCP using IRS standards.

4

Decision: Accept, Reject, or Counter

The IRS will either accept your offer as submitted, reject it (if your RCP exceeds your offer), or in some cases issue a counter. Acceptance requires payment per your chosen method. Rejection triggers your 30-day appeal window.

5

Post-Acceptance Compliance (5 Years)

After acceptance, you must stay in full tax compliance for 5 years: file all returns on time, pay all taxes owed, and make estimated payments if required. Defaulting on a settlement agreement can revive the original liability.

Critical: An OIC Tolls Your Collection Statute

Filing an OIC stops your 10-year collection clock (CSED) for the entire review period, plus 30 days after rejection. If your CSED is expiring in 1–2 years and the IRS has been inactive, filing an OIC can extend their collection window by the review period. Understand your CSED before filing. Use the CSED Clock Calculator first.

Source: IRM 5.8.1

OIC vs. Other Resolution Paths

OIC is not always the right answer. Compare it against other IRS programs based on your situation:

ProgramBest WhenTolls CSED?
Offer in CompromiseRCP significantly less than debt; CSED has years remainingYes — full review + 30 days
Installment AgreementDebt ≤$50k; can afford regular paymentsMinimal (request only)
Currently Not CollectibleZero ability to pay; CSED still running is a benefitNo — CSED keeps running
Wait for CSED ExpirationCSED expires in <2 years; IRS collection activity is minimalNo — no action means no tolling

What Tax Firms Don't Tell You

Many tax resolution firms advertise OIC heavily because it is easy to market — "settle your $100k debt for $100!" What they often leave out:

  • The IRS rejects OICs when your RCP meets or exceeds your liability. No amount of negotiation changes the math — the formula is fixed.
  • Firms sometimes file OICs they know will be rejected — just to buy time. While pending, the CSED is tolled, meaning the IRS gets extra time to collect after the rejection.
  • The OIC application is public government forms you can file yourself. The $205 fee goes to the IRS, not a firm. If you have a straightforward financial picture, self-filing is a real option.
  • Legitimate help from a CPA, EA, or tax attorney makes sense for complex cases — business income, multiple years, disputed liability. For simple W-2 situations, the IRS Pre-Qualifier tool and this guide may be sufficient to understand your position.

Calculate Your RCP First

Before spending time on Form 656, use the OIC Eligibility Calculator to see whether your RCP is lower than your total tax debt. If it is not, OIC is unlikely to be accepted and you should consider other resolution paths.

Open OIC Eligibility Calculator

Need Help Running the Numbers or Filing Form 656?

If your financial picture is complex — self-employment income, multiple tax years, business assets — a tax professional can verify your RCP and ensure your application is complete and accurate before submission.

Get a Professional Analysis

Frequently Asked Questions

What is an Offer in Compromise?
An Offer in Compromise (OIC) is a formal agreement under IRC § 7122 that allows you to settle your entire IRS tax debt for less than the full amount owed. The IRS accepts an OIC when it determines your Reasonable Collection Potential (RCP) is less than your total liability — meaning collecting everything you owe is unlikely before the 10-year collection statute expires.
How does the IRS decide what my minimum offer must be?
The IRS uses a formula called Reasonable Collection Potential (RCP). RCP = Quick Sale Value of your assets (roughly 80% of fair market value) + Future Income. Future income is your monthly disposable income (what's left after IRS-allowed expenses) multiplied by 12 (lump sum) or 24 (periodic payment). Your offer must equal or exceed your RCP for the IRS to consider it.
What is the difference between lump sum and periodic payment OIC?
A Lump Sum Offer requires 20% of the offer amount upfront with the application, and the remainder paid within 5 months of acceptance. Future income is multiplied by 12. A Periodic Payment Offer allows you to pay in monthly installments over 6–24 months during IRS review and after acceptance. Future income is multiplied by 24, making the minimum offer higher. Which to choose depends on your cash on hand and offer amount.
Does the OBBBA overtime deduction affect my OIC?
Yes. The One Big Beautiful Bill Act (P.L. 119-21) created an above-the-line deduction for qualified overtime pay — up to $12,500 for single filers and $25,000 for joint filers (phased out above $150,000/$300,000). This deduction reduces your Modified Disposable Income (MDI) in the OIC calculation, which lowers your Future Income component and thus your minimum offer amount.
What happens if the IRS rejects my offer?
You have 30 days from the rejection letter date to appeal through IRS Appeals (IRM 8.23). You can request a conference with an Appeals Officer who independently reviews your case. If Appeals also rejects it, you can refile an OIC with updated financials. Important: while your OIC is pending, the IRS collection statute (CSED) is tolled — it stops running. A denial extends that statute by the review period plus 30 days.
What if I can't pay the 20% upfront for a lump sum offer?
If you cannot afford the 20% initial payment, you have two options: (1) Choose the Periodic Payment method instead — no 20% upfront, but monthly installments during review and a higher multiplier (24 vs. 12); or (2) Apply for the Low-Income Certification waiver on Form 656-A, which waives both the $205 application fee and the initial payment requirement for taxpayers meeting IRS income guidelines.

IRS Sources