Offers in Compromise & Penalty Abatement

Negotiating tax debt settlements and penalty relief with the IRS

If you owe the IRS more than you can pay, an Offer in Compromise (OIC) may allow you to settle your tax debt for less than the full amount owed. Philip Falco, as a dual-licensed Attorney and CPA, has the tax expertise and legal skills to negotiate effectively with the IRS on your behalf.

What Is an Offer in Compromise?

An Offer in Compromise is an agreement between a taxpayer and the IRS that settles a tax liability for less than the full amount owed. The IRS considers an OIC when the taxpayer cannot pay the full amount, when there is doubt as to the amount owed, or when paying the full amount would create an economic hardship.

Eligibility Requirements

  • All required tax returns must be filed
  • All estimated tax payments for the current year must be current
  • You must not be in an open bankruptcy proceeding
  • You must have a valid extension for the current year's return (if applicable)

Penalty Abatement

IRS penalties can add significantly to your tax debt. Penalty abatement may be available if you can demonstrate reasonable cause for your failure to file or pay on time. Common grounds for penalty abatement include:

  • Reasonable cause — illness, natural disaster, death in the family, inability to obtain records
  • First-time penalty abatement — available to taxpayers with a clean compliance history
  • Statutory exception — specific IRS provisions that provide penalty relief
  • IRS error — penalties resulting from incorrect IRS advice or actions

Why Choose an Attorney for OIC Negotiations?

The OIC process involves detailed financial disclosures and legal arguments. As a licensed attorney, Philip Falco provides full attorney-client privilege protection during the negotiation process. As a CPA, he has the financial expertise to accurately present your case to the IRS.

Call (303) 626-7000 to discuss whether an Offer in Compromise or penalty abatement is right for your situation.

Ready to Get Started?

Contact Philip Falco, Attorney & CPA, for expert tax representation in Denver.