If you submitted an appeal of an Offer In Compromise and it gets rejected, where do you go from there?

Assuming your client’s offer in compromise was rejected by the IRS Offer Specialist assigned to their case, you have a few options.  You can appeal to the Specialist’s direct supervisor, the Group Manager. If you are unsuccessful you can request to argue your position to the Group Manager’s supervisor who is typically a Settlement Officer. If necessary, you can also reach out to IRS counsel. Keep in mind that to appeal at any level takes a significant amount of time and resources. If you plan on doing so make sure you are VERY confident that you have a strong argument to support your client’s position. Otherwise the path of least resistance and maybe the better choice may be to enter into a low-dollar installment agreement or placing your client into Currently-Non-Collectable (“CNC”) status and let the statute of limitations on collection run out. In the case of income taxes, discharging the taxes in bankruptcy may be an additional option.