Mike, most clients, if they can afford it, would prefer the OIC. There are however a few issues that would cause a taxpayer to go into the partial-pay instead, including:
1. The RCP for the Offer is a number they simply cannot pay, so the Offer is unattainable
2. They have a dissipated asset issue and so cannot do an Offer until they get past the three year look-back
3. The CSED is going to run soon and it will be less expensive to do the partial pay and run out the CSED rather than stop it by filing an Offer
