Form 656-L allows taxpayers to dispute tax liabilities when they believe the Internal Revenue Service has issued an incorrect tax assessment. Unlike other options under the offer program, this liability option does not address whether you can pay the total amount owed. Instead, it focuses on whether the IRS assessed the tax bill correctly. When errors in applying tax law or new supporting documents emerge, Form 656-L allows you to request a review of the disputed tax amount.

The compromise process under Form 656-L applies to specific situations, such as when a tax examiner misinterprets the tax code, when a tax return was reviewed without all the relevant records, or when exceptional circumstances prevented you from responding during the original assessment. Filing a liability offer often involves submitting amended tax return information, organizing employer identification number and social security number details, and ensuring all tax periods are clearly noted. A tax professional can assist in preparing the explanation and supporting evidence required.

While the offer section of Form 656-L does not guarantee relief in every case, it creates a formal path to resolve disagreements with the IRS. With proper documentation, taxpayers can ensure their claim receives a thorough evaluation by the IRS.

Eligibility Requirements for Form 656-L

Eligibility for Form 656-L depends on whether the Internal Revenue Service determines that a legitimate dispute exists over the accuracy of a tax assessment. This liability option is available for taxpayers who believe the IRS assessed a tax bill in error and can provide credible supporting documents to prove their claim. The form applies to individuals, wage earners, self-employed taxpayers, and businesses that wish to resolve liability offers for the same tax year. Meeting the requirements is essential because offers that do not meet IRS standards are returned without review.

  • A tax liability must exist where a genuine dispute arises from the assessment.
  • A written statement must identify why the IRS incorrectly assessed the tax amount.
  • Supporting documents must accompany the claim to demonstrate why the assessment does not match the facts or tax code.
  • The offer section of the form must state a tax amount of at least one dollar, even when the taxpayer believes nothing is owed.
  • A final court decision should not have resolved the matter since such cases are outside the IRS offer program.

Disqualification applies in several circumstances:

  • An open bankruptcy proceeding automatically prevents acceptance of a Form 656-L.
  • Duplicate liability offers for the same tax periods will be returned.
  • Submitting an offer solely to delay collection action is not considered valid.
  • Cases involving restitution ordered by the Department of Justice are ineligible for review.

The official Form 656-L and Instructions outline detailed eligibility requirements, submission rules, and signature standards, making it critical for taxpayers to understand these rules to avoid unnecessary delays. 

A well-prepared submission that addresses each eligibility condition increases the likelihood of review, while close attention to these requirements ensures taxpayers can use Form 656-L effectively. Preparing accurate claims supported by evidence provides the strongest opportunity for a fair assessment by the Internal Revenue Service.

Grounds for Doubt as to Liability

Form 656-L applies when taxpayers challenge whether the Internal Revenue Service assessed the correct tax liabilities. Doubt as to liability arises when the tax amount does not reflect proper application of the tax code or law. Establishing recognized grounds requires pointing to specific reasons and presenting supporting documents that show why the liability should be reduced or removed.

Common Grounds for Filing

  • Tax examiner errors: Misinterpreting the tax code, incorrect application of tax law, or oversight of key evidence during the assessment.

  • New supporting documents: Records such as receipts, bank statements, or affidavits discovered after the original assessment directly affect the tax return or amended tax return.

  • Procedural issues: Missed audit appointments due to exceptional circumstances, such as natural disasters or relocation without proper IRS notice.

  • Third-party misrepresentation: Incorrect or fraudulent information provided by employers, brokers, or other parties caused the IRS to assess the wrong tax amount.

  • Improper tax code application: Errors in applying credits, deductions, or liability allocation across tax periods or between wage earners and self-employed individuals.

  • Incorrect responsibility assignment: Holding the wrong individual accountable for a business-related tax bill, especially in employer identification number reporting cases.

  • Issues with amended return processing: IRS failure to consider a properly filed amended return that would have changed the original assessment.

Grounds for a liability offer must be clearly stated in the written explanation and backed by documentation that demonstrates the IRS assessed an inaccurate liability. Presenting precise reasons supported by reliable evidence gives the IRS a clear basis for evaluating whether compromise doubt applies. Addressing these grounds thoroughly allows the IRS to assess disputes under the offer program while ensuring the claim is consistent with the applicable tax law.

Required Written Statement and Supporting Documents

A successful Form 656-L submission depends heavily on the clarity and completeness of the written statement. The Internal Revenue Service expects taxpayers to explain why the assessed tax liabilities are incorrect. 

Each explanation should reference the applicable tax code or law, detail the error in the tax assessment, and identify the tax amount the taxpayer believes is accurate. A tax professional can assist in preparing this narrative so that it addresses each claim with precision.

Essential Elements of the Written Statement

The written statement must clearly explain the grounds for compromise doubt. It should identify the specific tax return or amended tax return being disputed, the tax periods in question, and the total amount the IRS assessed. 

Any claim must be fact-based, linking evidence directly to the assessment error. By setting out the reasoning in organized paragraphs, taxpayers create a clear path for the tax examiner to evaluate the liability offer.

Core Supporting Documents

Evidence is essential to demonstrate that the IRS incorrectly assessed liability. Examples include bank records, receipts, contracts, canceled checks, payroll data, and employer identification number records. 

For joint offer submissions, social security numbers and related financial records must be included. Business ledgers and invoices should be attached to support the claimed adjustments when self-employed taxpayers file. All documents should be arranged by tax periods and labeled clearly to make the connection to the written statement unmistakable.

Importance of Organization

The effectiveness of the liability option depends not only on the evidence but also on how it is presented. Submissions that include an indexed list of attachments, explanatory notes, and organized sections demonstrate professionalism and help the IRS examiner evaluate the claim efficiently. 

Strong documentation combined with a well-prepared written statement gives the Internal Revenue Service a complete picture of why the liability should be reconsidered. Presenting a thorough and well-organized package ensures the taxpayer’s position receives serious attention during the compromise process.

Step-by-Step Guide to Completing Form 656-L

Completing Form 656-L requires thorough preparation and accurate entries across sections. The Internal Revenue Service evaluates each claim based on the accuracy of the facts and the supporting documents. Accurate sequencing ensures disputed tax liabilities, assessment details, and required corrections are clearly presented.

Step 1: Provide Identifying Information

Provide complete identifying information for every taxpayer included in the claim. Enter legal name, mailing address, and contact details for each filer. Include the social security number or individual taxpayer identification number; list an employer identification number for self-employed filers.

Step 2: Specify Tax Periods and Returns

Specify tax periods and the type of tax return in dispute. Identify each year or quarter and note any amended tax return filed. Ensure IRS records link entries to the correct module.

  • List income, employment, or excise categories for accurate routing purposes.
  • Match each period to the assessed tax amount under dispute.
  • Include prior audit changes that affect liability across tax periods.

Step 3: State the Offer Amount

State the offer amount in the offer section based on the correct liability. Enter at least one dollar even when you believe the proper amount equals zero. Align the figure fully with the facts, supporting documents, and applicable tax law.

Step 4: Explain the Circumstances

Write an explanation that shows why the tax assessment is wrong. Identify specific errors and link each point to evidence and tax code. Organize the narrative for the tax examiner.

  • Explain how tax periods and amounts relate to each stated error.
  • Reference specific tax return schedules or amended tax return changes.
  • Describe why the Internal Revenue Service records require correction or removal.

Step 5: Attach Supporting Documents

Attach supporting documents aligned with the explanation. Include bank statements, payroll records, invoices, and correspondence addressing the disputed assessment. Organize files by tax periods, label each exhibit clearly with dates and identifiers, and ensure totals match the claimed tax amount.

Step 6: Complete Signatures and Declarations

Complete signatures and declarations for every taxpayer named in the offer. For a joint offer, both spouses must sign and date the form. Representatives must include authorization documents.

  • Use blue or black ink to ensure legible, acceptable signatures for processing.
  • Attach identification copies when requested to verify social security numbers and identity.

Review every entry before assembly to minimize processing delays. Ensure the mailing address is current for the assigned campus, and retain copies of everything submitted. A precise package helps the Internal Revenue Service assess the claim fairly. After completing the form, assemble the submission package for IRS review.

How to Submit Form 656-L to the IRS

Submitting Form 656-L requires following specific procedures so the Internal Revenue Service accepts the filing for review. The form must be complete and signed, and include documentation directly addressing the disputed tax liabilities—taxpayers who thoroughly prepare and organize their package increase the chance of timely review within the compromise process.

Mailing and Delivery Requirements

The IRS requires original signatures in blue or black ink, and electronic submissions are not accepted. Mail the completed form and all supporting documents to the designated processing center identified in the official Form 656-L guidance. Always verify that the mailing address matches the current IRS guidance for liability offers.

Key Items to Include

  • Completed Form 656-L: Signed and dated by all taxpayers, including joint offer participants.
  • Written statement: A clear explanation of why the IRS misjudged the tax bill.
  • Supporting documents: Records such as tax returns, amended tax return copies, or employer identification number filings that validate the claim.
  • Authorization forms: Include Form 2848 or 8821 when a tax professional represents you.
  • Index of exhibits: Organize attachments by tax periods and label them clearly.

Processing Timeline

Once received, the IRS records the package, enters it into the Automated Offer in Compromise system, and performs a processability review. Liability offers that meet the requirements advance to a detailed review, where a tax examiner evaluates the assessment and supporting documents, with guidance on internal procedures for processing Form 656-L, as detailed in the Internal Revenue Manual 5.19.24

Adhering to these submission steps ensures the IRS can evaluate the liability option immediately. At the same time, a precise package demonstrates serious intent to resolve disputed assessments and supports a fair compromise process.

Common Mistakes to Avoid

Taxpayers preparing a Form 656-L often encounter errors that slow down or prevent proper evaluation by the Internal Revenue Service. Many of these mistakes stem from incomplete paperwork, inaccurate entries, or poor supporting document organization. Identifying these issues can help taxpayers present a stronger liability offer for review.

  • Submissions missing original signatures are rejected immediately. Each taxpayer must sign and date the form for joint offers in original ink.

  • Incorrect mailing address: Sending the form to the wrong processing center delays review and risks expiration of the collection period. Confirm the correct mailing location before submitting.

  • Missing supporting documents: Claims without bank records, receipts, or amended tax return copies do not provide enough evidence to challenge an IRS-assessed liability. Organized exhibits demonstrate the validity of the dispute.

  • Improper offer amount: Leaving the offer section blank or stating zero violates program rules. Even when you believe no tax is owed, a minimum of one dollar must be entered.

  • Filing during an open bankruptcy proceeding: Any liability offer submitted while bankruptcy is active will be returned unprocessed. Verify bankruptcy status before filing.

  • Poor document organization: Disorganized or unlabeled attachments complicate review for the tax examiner. Numbered exhibits tied directly to the written statement provide clarity and efficiency.

Avoiding these errors ensures the Internal Revenue Service can properly assess whether compromise doubt applies. Organized submissions with accurate entries and well-documented evidence increase the likelihood of a fair review. Presenting a complete and professional package also helps the claim move efficiently through the review process.

Form 656-L vs. Form 656

The Internal Revenue Service provides different compromise programs depending on taxpayers' circumstances. Form 656-L applies when the tax assessment may be inaccurate. Form 656 applies when the assessment is correct, but the taxpayer cannot pay the full amount. Understanding these differences allows taxpayers to identify the form corresponding to their situation.

Comparison of Key Features

1. Purpose

  • Form 656-L (Doubt as to Liability): Filed when a taxpayer believes the IRS incorrectly assessed the tax bill under the law or tax code.
  • Form 656 (Doubt as to Collectibility): Filed when the taxpayer agrees the tax is owed but cannot pay the full amount.

2. Eligibility

  • Form 656-L: Available only if no final court decision has been issued and no open bankruptcy proceeding exists.
  • Form 656: Available if the taxpayer can demonstrate financial hardship and inability to pay the assessed liability.

3. Offer Amount

  • Form 656-L: Must state a minimum offer of at least one dollar, even if the correct tax owed is zero.
  • Form 656: Based on calculations of income, assets, and projected future earning capacity.

4. Supporting Documents

  • Form 656-L: Requires a written statement plus proof such as receipts, amended tax returns, or employer identification records.
  • Form 656: Requires financial statements, wage documentation, or profit-and-loss records for the self-employed.

5. Application Fee

  • Form 656-L: No application fee required.
  • Form 656: Fee required, unless the taxpayer qualifies under low-income guidelines.

Selecting the correct form ensures the IRS considers the claim under the proper framework. Filing the wrong option may cause processing delays or rejection without review. Taxpayers should carefully examine their circumstances and use the form that addresses liability disputes or ability-to-pay concerns.

Interaction with Other IRS Relief Options

Form 656-L allows taxpayers to dispute incorrect tax liabilities, but does not operate in isolation. The Internal Revenue Service provides several other relief paths that may overlap with or precede a liability offer. Understanding these programs enables taxpayers to use the relief program that applies to their circumstances.

Effective Tax Administration

Effective Tax Administration applies when the IRS agrees the assessment is correct but determines that collecting the full amount would create exceptional circumstances. This option often relates to situations where collection would undermine fairness or cause severe hardship for wage earners. While different from a liability option, it shares the goal of providing resolution within the broader offer program.

Injured Spouse Allocation

When one spouse’s share of a refund is taken to satisfy the other spouse’s debt, an injured spouse allocation may apply. This process protects the non-liable spouse’s portion of the refund. It functions separately from liability offers, which address whether the IRS assessed the tax bill correctly in the first place.

Collection Period

The IRS has a limited timeframe, called the collection period, to collect assessed liabilities. Filing a liability offer does not eliminate this timeframe, although specific actions may extend it. Publication 594—The IRS Collection Process guides how liens, levies, and appeal rights affect the collection period.

Amended Return

When errors result from a taxpayer’s filing, the appropriate corrective measure is an amended tax return rather than a liability offer. An amended return allows the IRS to evaluate corrected information and issue a revised assessment. This distinction ensures that taxpayers apply the proper remedy for their situation.

Understanding how Form 656-L interacts with these programs helps taxpayers align their strategy with IRS requirements. Reviewing eligibility and documentation needs for each relief option ensures the dispute is addressed under the most effective procedure.

Professional Help and Free Resources

Navigating a Form 656-L claim often feels overwhelming for taxpayers managing disputed tax liabilities. Complex requirements, detailed supporting documents, and strict IRS standards make professional guidance valuable. A tax professional can clarify whether the IRS assessed the tax bill correctly and assist in preparing a liability offer that meets program expectations.

Taxpayers may benefit from professional assistance or free resources in the following ways:

  • Enrolled agents, certified public accountants, and tax attorneys provide expertise in tax law and IRS procedure. Their role is essential when disputed tax periods involve high balances or detailed financial records.

  • Low-income taxpayer Clinics offer representation at little or no cost for eligible wage earners and self-employed individuals. These clinics also assist with language access, helping taxpayers present a clear written statement and supporting documents.

  • The Taxpayer Advocate Service supports individuals experiencing delays or improper collection action. This independent office within the IRS helps ensure fair treatment and resolution of systemic issues.

  • Community programs, including Volunteer Income Tax Assistance sites, provide free help with tax return preparation and guidance on filing amended tax returns when necessary.

Selecting the right resource depends on the taxpayer’s situation, financial capacity, and complexity of the disputed assessment. Professional assistance increases the likelihood that the IRS will review a submission carefully, while free resources ensure that all taxpayers have access to support regardless of income. Using these options thoughtfully helps taxpayers resolve liability offers and ensures compliance with the compromise process.

Frequently Asked Questions

How does Form 656-L help if I believe my tax bill is wrong?

Form 656-L allows taxpayers to challenge a tax bill when the Internal Revenue Service incorrectly assesses liability. Instead of focusing on the inability to make a payment, this option addresses errors in the underlying calculation. You must submit a written explanation with supporting documentation showing why the assessment is incorrect. The IRS then reviews the claim to determine if compromise doubt applies.

Can I file Form 656-L if I already submitted an amended tax return?

Yes, an amended tax return can strengthen a Form 656-L if the IRS failed to consider it properly during the original assessment. If the amended filing presents new evidence that reduces the tax bill, it should be included with the liability offer. This ensures the tax examiner has a complete record. Supporting documentation must be directly linked to the amended return to confirm the changes made.

What role does audit reconsideration play before filing Form 656-L?

Audit reconsideration is often recommended when the IRS issued an assessment you believe is inaccurate and you now have new evidence. If the reconsideration does not resolve the liability dispute, you may file a Form 656-L. Providing organized supporting documentation during both steps helps clarify your position. Filing in this sequence ensures the IRS thoroughly reviews information before evaluating a liability offer.

How does the “one offer” rule apply to Form 656-L?

The IRS allows only one offer for the same tax periods. If you submit a Form 656-L while another offer in compromise is pending, the liability option will not be processed. Taxpayers must choose between compromise, doubt, or other relief requests. Careful evaluation of the offer section and supporting documentation helps determine whether the claim aligns with the program's best interests.

Do I need to make a payment with Form 656-L?

Form 656-L does not require an upfront payment, unlike other types of offers in compromise. The offer section must still list at least one dollar, even if you believe no tax is owed. This minimum amount ensures compliance with program rules. If the IRS accepts the offer, the final agreement may require you to pay the liability amount determined by reviewing the supporting documentation.

How does interest factor into a Form 656-L liability offer?

Interest accrues on unpaid balances until the IRS resolves the assessment. If you demonstrate through supporting documentation that the tax bill was overstated, related interest may also be reduced. The liability offer must clearly explain how the error affected the base tax and the accumulated interest. Ensuring accurate records for each tax return period strengthens the claim during the offer in compromise review.

Is professional guidance in my best interest when filing a Form 656-L?

Professional assistance may be beneficial when navigating the compromise process. A tax professional helps evaluate whether audit reconsideration, amended tax return filings, or other relief may resolve the issue without filing. They organize supporting documentation for the offer section if a liability option is pursued. Their expertise ensures the IRS receives a well-prepared package that meets program standards and effectively addresses the disputed tax bill.