The offer in compromise process is generally a very lengthy one. I described the offer in compromise process in a previous post.

There are some situations where you can theoretically have an offer in compromise submitted and a decision made within 90 days. This is by following the emergency offer in compromise procedures outlined in the Internal Revenue Manual §5.8.2.6.

This procedure is allowed in an emergency situation or perceived emergency situation. The IRS lists a few examples including:

• A contract or business agreement requiring the taxpayer, as a condition of the contract or agreement, to resolve the tax liability by a specific date.
• Availability of the money to fund the offer is limited to a certain time.
• A terminal illness may affect the ability to complete the payment terms.

Once an offer in compromise is submitted with an “emergency request” the IRS manager will review it to make sure it deserves the special treatment. The IRS is to make “every effort” to close the offer in compromise within 90 days. However, the taxpayer must be ready, willing and able to provide documents to the IRS at their request and at warp speed for the emergency review to go to completion within 90 days.