You may submit an Offer in Compromise (OIC) as part of a Collection Due Process hearing at IRS Appeals. One big advantage in doing so is your right to challenge a denial of the OIC in Tax Court; you do not have this right if you submit an OIC through the normal channels. Often times, you also get a more experienced and trained Appeals Officer working your OIC and not just looking for reasons to return it or deny it. Moreover, an Appeals Officer must consider the merits of the OIC. As illustrated in the Mason case, Mason v. Commissioner, T.C.M. 2021-64, an Appeals Officer must truly consider the full merits of an OIC and cannot just rely on a prior decision to return the OIC by a previously assigned Revenue Officer.
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