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IRS & Financial ConsultingLas Vegas, NV· Restaurant owner (S-corp)
$248K IRS Liability Settled for $72K via Offer in Compromise
$248K
Liability settled
$72K (29%)
Settlement amount
$0
Personal TFRP exposure
The challenge
A Vegas restaurateur emerged from the pandemic with $248,000 in combined payroll and income tax liabilities. The IRS had filed a Notice of Federal Tax Lien and was threatening 6672 trust-fund recovery penalties against him personally.
Our approach
- Filed all delinquent 941s and 1120-S returns to reach full compliance.
- Negotiated a temporary collection hold during OIC preparation.
- Prepared Form 656 with Doubt as to Collectibility basis and Form 433-B (business) + 433-A (individual).
- Calculated Reasonable Collection Potential at $68,400 based on quick-sale asset value + 12 months future income.
- Defended the offer through two IRS counter-proposals.
The outcome
OIC accepted at $72,000 — settling $248,000 in liabilities for 29 cents on the dollar. NFTL withdrawn 30 days after final payment. No personal trust-fund recovery penalty assessed.
I thought I was going to lose the restaurant. They got me a settlement I could actually pay.