Practitioners considering making an offer in compromise to the Internal Revenue Service on behalf of a client are faced with significant changes to the program. While negotiating an OIC has not been an option for most taxpayers, the changes in several key features mean that it will no longer be a feasible option for some.Topping those new OIC guidelines is a rule in which taxpayers filing a lump-sum offer must pay a non-refundable deposit of 20 percent of the offer amount with the application.

That upfront payment may be too steep for many taxpayers in trouble, say experts. "The 20 percent nonrefundable deposit will stop all offers funded by a mortgage on property, or large-dollar offers where the deposit exceeds $250,000," said Dave Levine, an enrolled agent in Reno, Nev., and a former IRS revenue officer. "For the past few months, I've been telling my clients that if the debt is over $100,000, plan on going through the appeals process, since large-dollar offers are seldom approved at the lower levels."

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