What is an “Effective Tax Administration,” or ETA Offer?

An ETA Offer is an offer where the taxpayer, on paper, can full-pay the tax liability but there are public policy reasons and/or special circumstances that justify the IRS accepting less than the full-amount owed. These special circumstances can include that the taxpayer was a victim of a crime (like payroll embezzlement), the taxpayer will be placed in economic hardship if they are required to full-pay the tax liability, or there are some special medical or other reasons the IRS needs to consider.