What are the differences between the types of Offers-in-Compromise?

– Doubt-as-to-Collectability Offer: this is an Offer where the taxpayer does not dispute the amount owed in back taxes, but cannot afford to pay the tax debt back in full. The taxpayer makes an Offer to the IRS based upon their particular financial circumstances and provides back-up to support their proposal.
– Doubt-as-to-Liability Offer: this is an Offer where the taxpayer offers to settle the debt based upon being able to show they do not actually owe all of the underlying tax. In many ways a Doubt-as-to-Liability Offer is similar to audit reconsideration. Here the taxpayer provides documentation as to why they do not owe the money the IRS claims.
– Effective Tax Administration: An ETA Offer-in-Compromise is an Offer in which the taxpayer can full-pay the tax but where, for public policy reasons, the IRS should not require them to do so and should accept less than the full amount due.