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
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
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
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
Preparing supporting materials
What is included
IRS authority and references
Important court distinction
Client perspective
Proof from Google reviews
5.0 average · 105 Google reviews · ebotCPA, Irving, TX
“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.”
“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.”
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)
