Doubt as to Liability vs. Doubt as to Collectibility
Two offers in compromise, two forms, and one question that decides which: are you saying the tax is wrong, or that you cannot pay it?
Quick Answer
One question separates them and the IRS puts the answer in capitals on the form: "If you agree that you owe the tax but cannot afford to pay, DON'T FILE a Form 656-L." Doubt as to liability disputes the tax; doubt as to collectibility accepts it and disputes the ability to pay. Everything else follows from that. The liability offer needs no financial disclosure, no application fee and no deposit, and needs evidence that the tax is wrong. The collectibility offer needs the opposite: a fee and an initial payment unless the low-income certification applies, and a full account of what you have and earn. Filing the wrong one does not get redirected — the IRS states a DATL offer submitted without a written explanation and supporting documentation is returned without further consideration.
Doubt as to liability (Form 656-L)
Advantages
- No application fee and no deposit. The IRS states "No deposit or application fee is required for a DATL offer" and says explicitly not to include any payment with the form.
- The offer amount reflects what you believe the tax should be. The IRS states your offer "should reflect the amount of tax you believe is correct".
- It does not depend on your finances at all.
- The minimum is nominal: the IRS states you must submit an offer for $1.00 or more.
Disadvantages
- It requires evidence. The IRS states you must provide a written statement explaining why all or part of the tax debt is incorrect, with supporting documentation, and that failure to do so "will result in the return of your offer without further consideration".
- Two circumstances rule it out. The IRS states a DATL offer cannot be considered where the liability has been established by a final court decision or judgment, or where the assessed tax is based on current law.
- Sequencing matters. The IRS states that if another IRS function is addressing the liability — audit reconsideration, for example — you must wait until that process is complete.
- The IRS states that payments received "will not be returned and will be applied to the tax liability".
Best For
What it argues: the tax is wrong.
Typical Cost
The IRS states no application fee or deposit applies to a doubt-as-to-liability offer.
Doubt as to collectibility (Form 656)
Advantages
- It is the route where the tax is not in dispute. The IRS describes an offer in compromise as allowing you to settle for less than the full amount where you cannot pay in full or paying would create a financial hardship.
- The IRS names the factors it weighs: ability to pay, income, expenses and asset equity.
- It publishes a low-income certification that removes the application fee and the initial payment.
Disadvantages
- An application fee and an initial payment apply unless the low-income certification does.
- It requires full financial disclosure.
- The IRS states it generally approves an offer when the amount offered "represents the most we can expect to collect within a reasonable period of time" — a judgement on your full financial position.
- The IRS states plainly: "The Offer in Compromise Program is not for everyone."
Best For
What it argues: the tax is right and cannot be collected in full.
Typical Cost
An application fee and an initial payment apply unless the IRS low-income certification does. The IRS publishes the current amounts.
The Verdict
One question separates them and the IRS puts the answer in capitals on the form: "If you agree that you owe the tax but cannot afford to pay, DON'T FILE a Form 656-L." Doubt as to liability disputes the tax; doubt as to collectibility accepts it and disputes the ability to pay. Everything else follows from that. The liability offer needs no financial disclosure, no application fee and no deposit, and needs evidence that the tax is wrong. The collectibility offer needs the opposite: a fee and an initial payment unless the low-income certification applies, and a full account of what you have and earn. Filing the wrong one does not get redirected — the IRS states a DATL offer submitted without a written explanation and supporting documentation is returned without further consideration.
Frequently Asked Questions
What counts as doubt as to liability?
When can a liability offer not be considered?
Is there a fee?
What if I am already dealing with the IRS on the same issue?
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Sources
- Form 656-L, Offer in Compromise (Doubt as to Liability) — Internal Revenue Service, retrieved 2026-08-21
- Offer in compromise — Internal Revenue Service, retrieved 2026-08-21
- Form 13711, Request for Appeal of Offer in Compromise — Internal Revenue Service, retrieved 2026-08-21
Sourced to primary IRS materials and editorially reviewed. Not reviewed by a tax professional. Not tax advice. Report a correction.