I am not sure it makes sense:
1. If you do an Offer you are almost better off with a higher balance (less likely the taxpayer can pay in full), and
2. After an Offer the taxpayer had better not get penalized for the next 5 years or they void the offer.
Usually if we do an OIC we are not concerned about getting penalties abated.
Thanks. I didn’t do the OIC. The taxpayer is now coming to me to complain about the short term deferred payments. There is a year that is eligible for FTA. I was wondering if an OIC closes the door to FTA’s.