Date: November 17th, 2017 8:35 PM
Author: contagious cowardly digit ratio
You basically have three angles: (1) doubt as to liability, (2) doubt as to collectability, (3) effective tax administration.
Doubt as to liability means that the taxpayer has not had an opportunity to contest the underlying liability. If you can establish this then you can dispute the assessed tax and possibly get it lowered.
The basic premise of doubt as to collectibility is thus: there is a 10 year collection statute of limitations. This is from the date of assessment, not the date of return filing or the due date of the return. You are going to want to use a Form 433-A for individuals or 433-B for businesses and assess the reasonable collection potential. That basically means, how much could the IRS reasonably expect to collect over the life of the collection statute?
If a taxpayer is working age and in reasonably good health, the IRS is usually not keen on accepting OICs on this basis. Keep in mind that the IRS has extraordinary creditor's rights including silent liens and the right to seize property after notice. But I also say this with the caveat that you never know the talent level of the person at the IRS who is considering these (unfortunately).
The third is effective tax administration which basically means that the taxpayer does not contest the liability and has the means to pay but some other pressing concern overrides this and weighs in favor of settling the debt.
That is the basics of it. I handle this on the IRS side so I can't help you as far as what to charge.
(http://www.autoadmit.com/thread.php?thread_id=3801086&forum_id=2#34713560)