An Inside Look at the IRS
Offer in Compromise Program
The IRS Offer in Compromise (OIC) program is frequently misunderstood even by experienced tax practitioners. This two-hour self-study IRS continuing-education course provides an inside look at how offer examiners and managers evaluate collectibility, reasonable collection potential, financial disclosures, economic-hardship claims, and proposed full-pay determinations. Participants will also examine rejected offers, IRS Appeals review, and Offers in Compromise submitted during Collection Due Process hearings.
This session provides a rare, inside look at how Offers are actually evaluated within the IRS. Led by two former IRS Revenue Officers—including a former Offer in Compromise group manager and Appeals Settlement Officer—the course explains how OIC cases are evaluated from inside the IRS Collection function. Attendees will learn the internal workflow from submission to recommendation, the practical meaning of “reasonable collection potential,” how to respond when the examiner proposes full pay, and how Appeals handles OICs submitted as part of a CDP hearing.
We will also cover when to raise the offer amount, when to push back with supporting evidence, and when to withdraw and pivot to a different collection alternative. If you want to understand how OIC decisions are actually made, not just how they’re described in the IRM, this course will show you the process from the IRS side of the table.
After completing this course, participants should be able to:
Differentiate between Doubt as to Collectability, Doubt as to Liability, and Effective Tax Administration offers, and identify when each basis is most appropriate in practice.
Explain how the IRS calculates Reasonable Collection Potential (RCP) and evaluate how income, expenses, equity, and dissipated assets impact an offer’s viability.
Interpret the internal workflow of an Offer in Compromise from initial submission through review, recommendation, and final approval within IRS Collection and Appeals.
Assess examiner findings and formulate effective written responses, including when to provide additional documentation, when to adjust the offer amount, and when to withdraw the offer.
Apply strategic considerations when submitting an Offer in Compromise during a Collection Due Process (CDP) hearing and anticipate how Appeals coordinates with COIC.
Recognize the practical indicators of a strong versus weak offer package and identify common errors that lead to unnecessary delays, returns, and rejections.
Who should Attend:
This course is designed for enrolled agents, CPAs, tax attorneys, tax-resolution practitioners, collection representatives, and other professionals who evaluate, prepare, negotiate, or appeal IRS Offers in Compromise.
IRS CE Credit: 2 Hours
Your Instructor
Peter Salinger
Tax Consultant
Peter Salinger worked for the IRS for over thirty-three years. He retired January 31, 2020. He started Salinger Tax Consultants in February 2020.
Peter was a field revenue officer. After several years he was promoted to a revenue officer group manager. Several years after that he was promoted to a branch chief position. This was a mid level management position where he managed five first line managers that oversaw seventy-five revenue officers.
Peter also managed an offer in compromise group where he was responsible for all of the offer in compromises that were assigned to the Manhattan district office. He reviewed offers that were recommended for acceptance or rejection. As a first line manager he also reviewed cases in process and provided feedback to his employees. Manhattan eventually added a second offer in compromise group to the office. In his capacity as a branch chief Peter oversaw both of those groups. Peter also conducted various training and continuing education classes as well as outreach seminars for external stakeholders.
In 2001 Peter left Manhattan and the Collection Division. He transferred to the Tampa Florida office and became the first Appeals Settlement Officer there. Peter worked the various workstreams in Appeals (CDP, CAP, TFRP, penalty appeals, and OIC). Peter was the main reviewer in the office for offers that were rejected by Compliance. Peter also spent several years working international collection cases in Appeals where the Service was trying to collect against taxpayers that resided outside of the United States.
Peter estimates that he reviewed over 3500 offers during his IRS career.
Peter is also co-author of the best selling Amazon book Exposing the Secrets for IRS Settlements
Peter received his EA in 2020
Michael Sullivan
Tax Consultant
Former IRS Agent | Founder, MD Sullivan Tax Firm
Michael D. Sullivan is a former IRS Revenue Officer with 10 years of federal service and more than four decades in private practice. At the IRS, he specialized in Offer in Compromise cases, handled large-dollar collection matters, and supported U.S. Attorney’s Office undercover operations. He earned multiple awards for his investigative work and served as a certified IRS instructor, training new agents across the Atlanta region.
For over 40 years, Michael has led a national tax-resolution practice advising high-net-worth clients, corporations and individuals on complex audit and collection matters. He is the co-author of Exposing The Secrets For IRS Settlements, which pulls back the curtain on the tax-resolution industry and the Offer in Compromise program. His YouTube channel, @HELP FROM A FORMER IRS AGENT, has more than 7,000 subscribers and over 300,000 watch hours.
Michael is also a frequent media contributor, appearing on Fox Business, ABC, Newsmax, NewsNation and other national platforms. He serves on leadership boards in the tax-profession community, hosts a 4,100-member Facebook group (“The Tax Mob powered by MDSULLIVAN LLC”), and moderates IRS forums.
Passionate and driven, Michael remains committed to helping taxpayers and supporting the next generation of tax-resolution specialists.
This course must be completed by 12/31/2026 to receive Continuing Education Credit
Self Study: An Inside Look at the IRS Offer in Compromise Program
** This course is only available for IRS CE. It is not available for CPA CPE at this time.
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