ebotCPA — The Entrepreneur's CPA

    You have records that may challenge the assessed tax

    A doubt-as-to-liability offer addresses a genuine dispute about whether the assessed tax is legally correct. Evidence is central to the review, and the IRS decides whether the offer meets its standards.

    How it works

    1. 1

      Identify the assessment issue

      We review the assessment, notices, tax periods and records that relate to the disputed amount. We distinguish a liability dispute from an inability-to-pay request.

    2. 2

      Evaluate supporting evidence

      We compare source documents with the IRS calculation and applicable tax treatment. We identify records or procedural details that need further review.

    3. 3

      Prepare the appropriate response

      If this route is appropriate, we prepare the agreed submission, including Form 656-L when applicable. The IRS reviews the evidence and makes its decision.

    Which sounds like you?

    The IRS used incorrect income information

    Your records may show income was reported incorrectly or never received.

    A deduction or credit was disallowed

    You have documentation relevant to a disputed deduction or credit.

    The assessment may involve identity theft

    A fraudulent return or income item may have been attributed to you.

    The IRS may have applied the wrong tax rule

    You have records that could change how the assessment should be calculated.

    What we do

    Assessing a liability dispute

    A doubt-as-to-liability matter requires evidence that the assessment is incorrect, not only that payment is difficult. • Compare the IRS assessment with returns, notices and source records. • Identify disputed income, deductions, credits or taxpayer identity. • Consider whether Form 14039 for identity theft or another account correction is more suitable. • Determine whether a final court decision affects the available route. You receive an issue summary, evidence checklist and explanation of possible next steps.

    Preparing supporting materials

    The submission should connect each disputed item to clear supporting records. • Organize relevant statements, receipts and third-party documents. • Explain the calculation or legal issue being challenged. • Prepare the agreed submission, including Form 656-L when appropriate. • Address requests for information within the agreed scope. You receive a copy of the completed submission and a record of the materials provided.

    What is included

    The scope depends on the disputed periods, the available evidence and any prior decisions. • Review of the relevant assessment and IRS correspondence. • Analysis of supporting records and the stated liability issue. • Preparation of the agreed Form 656-L materials where appropriate. • IRS communication within the agreed representation scope. • Form 656-L does not require an application fee or initial payment; Case Analysis pricing information: Free — Free Notice Decoder / free path. The free decoder explains your notice from its type and date. No documents are uploaded at the free step. $97 — Notice Review. Send us your IRS notice along with your own transcripts. We tell you what the notice is, what it means, and what the issues appear to be at a high level. This is information, not tax advice. $497 — Case Analysis. We pull your transcripts, analyze your whole situation, and give you a written do-it-yourself plan. $1,000 — Representation. Power of attorney (Form 2848) and we represent you before the IRS. Flat $1,000. The $97 Notice Review is credited toward the $497 Case Analysis. Fixed fees, confirmed in writing before work begins. Not a guarantee of any IRS outcome. We never charge a percentage of tax saved. You receive a written scope and fee terms before representation begins.

    IRS authority and references

    These authorities address compromise grounds and doubt-as-to-liability procedures. You receive the references relevant to the agreed scope.

    Important court distinction

    A liability established by a final Tax Court or other court decision is not available for a doubt-as-to-liability offer. Tax Court representation requires counsel admitted to practice before the United States Tax Court. You receive clarification of this distinction for the facts reviewed.

    Client perspective

    Proof from Google reviews

    5.0 average · 105 Google reviews · ebotCPA, Irving, TX

    Read all reviews

    “EbotCPA made filing my taxes so much easier than I expected! They explained everything in a way that was easy to understand, caught deductions I didn't even know I qualified for, and made the whole process stress-free. Super responsive.”

    Harrison NdetanTax Preparation · Google

    “Working with Mr. Ebot has been an absolute pleasure. He is highly knowledgeable, detail-oriented, and makes the tax process simple and stress-free. His professionalism, responsiveness, and genuine care for his clients really set him apart.”

    Ndohnwi MomaTax Strategy & Planning · Google

    Published pricing

    These are the current published fees from our service catalog. We confirm final scope and any quoted add-ons in writing before work starts. The $97 Notice Review is credited toward the $497 Case Analysis. Fixed fees, confirmed in writing before work begins. Not a guarantee of any IRS outcome. We never charge a percentage of tax saved.

    Free Notice Decoder / free path

    The free decoder explains your notice from its type and date. No documents are uploaded at the free step.

    Free

    Notice Review

    Send us your IRS notice along with your own transcripts. We tell you what the notice is, what it means, and what the issues appear to be at a high level. This is information, not tax advice.

    $97

    Case Analysis

    We pull your transcripts, analyze your whole situation, and give you a written do-it-yourself plan.

    $497

    Representation

    Power of attorney (Form 2848) and we represent you before the IRS. Flat $1,000.

    $1,000

    Resolution work

    Final scope depends on work type and amount owed.

    Fixed by work type and amount owed

    Common questions

    What happens before offer in compromise: doubt as to liability work begins?

    We discuss your goals and records, confirm the engagement scope and fee in writing, and identify deadlines before substantive work starts.

    How do you determine the fee?

    Current catalog amounts and quote terms are listed in Published pricing above. We confirm the agreed work, responsibilities, and any quoted scope in writing before engagement.

    What records should I prepare?

    The records depend on your situation. We provide a focused request list after confirming the work and reporting period.

    Authority and standards
    • IRC § 7122(a) · Compromise AuthorityAuthorizes IRS to compromise liability when there is doubt as to liability
    • IRM 4.18 · Doubt as to LiabilityIRM 4.18 — IRS procedures for evaluating DATL offers
    • Treas. Reg. § 301.7122-1(b)(1) · DATL GroundsRegulatory basis for doubt as to liability compromises
    • Form 656-L · DATL Application FormSpecific form for doubt as to liability offers (no $205 fee required)

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