There is a type of Offer that can be used in certain situations. I am referring to the Offer based on Effective Tax Administration. It is appropriate when the taxpayer has the funds or assets to pay the amount owed, but for public policy reasons, the IRS will accept less than the full amount. In the case of a personal injury settlement, for insance, if the taxpayer was severely injured and is now disabled and must depend on this settlement to live the remainder of his life, we might convince the IRS to accept a reasonable amount in the Offer to keep the taxpayer from becoming a welfare citizen. In other words, his money would be better spent on maintaining him rather than paying off the old tax debt. Of course, reasons other than disability might validate such an Offer also.