For the Form 656, Offer in Compromise, Section 3, "Reason for Offer" has two options.
The majority of applicants select: "Doubt as to Collectibility". The second option is: "Exceptional Circumstances (Effective Tax Administration)." IRS defines "Exceptional Circumstances" as follows:
"I owe this amount and have sufficient assets to pay the full amount, but due to my exceptional circumstances, requiring full payment would cause an economic hardship OR would be unfair and inequitable. I am submitting a written narrative explaining my circumstances."
During a recent OIC Appeals Settlement conference with a very experienced, Settlement Officer, he stated the following: "In my very long career I have seen very few Exceptional Circumstances (Effective Tax Adminstration) sustained by Appeals!"
Based upon this quote, it would appear that in the future, it will be not impossible, but very difficult to have the IRS accept an Exceptional Circumstances OIC.
Each taxpayer's circumstances are unique, and t if you beliieve, you would qualify, please contact me for an office consultation.