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                                                                                     Publication 220(12/16)

                                   Offer in Compromise Program
The New York State Offer in Compromise Program is designed             Individuals seeking relief based on undue economic hardship 
to help financially distressed taxpayers who face overwhelming        must include a statement explaining why paying the full 
tax liabilities. This includes any liability administered by the Tax  amount would cause undue economic hardship. Include any 
Department. Taxpayers accepted into the program may pay               supporting documents.
a reasonable amount as a compromise, satisfying the debt             Send the forms, and any required statements and documents, 
in full. While we carefully review and consider every offer in       to:
compromise, we do not accept all offers. While reviewing an 
offer, we may continue efforts to collect the debt.                     NYS TAX DEPARTMENT
                                                                        CED OFFER IN COMPROMISE UNIT
If the fixed and final amount owed is more than $100,000 (not           W A HARRIMAN CAMPUS
including interest and penalties), a New York State Supreme             ALBANY NY 12227-5100
Court justice must approve the offer in compromise.
                                                                     We will send confirmation when we receive the documentation. 
                                                                     If all required statements and documents are not included, we 
Who is eligible?                                                     will notify the taxpayer that the application is not complete. If the 
Generally, we may consider offers in compromise from the             missing material does not arrive within a specified time, we will 
following taxpayers:                                                 not process the application.
  individuals and businesses discharged from bankruptcy
  individuals and businesses that are insolvent (liabilities,       May a taxpayer withdraw an offer in 
 including tax liabilities, exceed the fair market value of assets)  compromise?
  individuals (not businesses) for whom paying the debt in full     A taxpayer or representative may withdraw an offer any time 
 would cause undue economic hardship                                 before our final decision. If we request information and it does 
                                                                     not arrive within a reasonable amount of time, we will consider 
To participate, taxpayers must have filed all required New York      the offer as withdrawn.
State tax returns.
The amount taxpayers propose as a compromise must be                 If we accept the offer in compromise:
an amount we realistically expect we could collect within            If we accept the offer, we will provide a written notification 
a reasonable period of time. It is based on the total value          detailing the terms and conditions, including:
of assets and the amount we could expect to collect from               Taxpayers agree to remain fully compliant with all Tax Law 
anticipated future income. Otherwise, the amount proposed             requirements, including filing returns and paying tax when 
must be justified by information the taxpayer submits.                required, for the next five years.
                                                                       If there are any tax refunds, offsets, credits, or funds payable 
What is undue economic hardship?                                      to taxpayers that are available to New York State (for 
Generally, undue economic hardship means that an individual           example, lottery offsets and unclaimed funds), for periods 
taxpayer is unable to pay reasonable basic living expenses,           before and including the calendar year in which we accepted 
which are those providing for the health, welfare, and production     the offer, we will apply them to the original outstanding liability. 
of income for their family. We use Internal Revenue Service           If there is any excess, we will refund it to the taxpayer.
(IRS) standards to help determine your allowable basic living 
expenses.                                                              Taxpayers waive any statute of limitations defenses 
                                                                      against the assessment and collection of the liability being 
We consider other factors, including:                                 compromised. Taxpayers also waive any statute of limitations 
  age, employment status, and employment history                     defenses against the issuance of new assessments for the 
                                                                      compromised liability in the event a taxpayer fails to comply 
  inability to earn income because of long-term illness, medical     with the terms of the offer.
 condition, or disability
                                                                       Taxpayers agree to forfeit any current capital loss or net 
  obligations to dependents                                          operating loss credits taken on any future New York State tax 
  extraordinary circumstances, such as special educational           returns.
 expenses, medical catastrophe, or natural disaster
  inability to borrow against or liquidate assets due to hardship   If we do not accept the offer in compromise:
Undue economic hardship does not include an inability to             If we do not accept the offer, we will notify the taxpayer or 
maintain an affluent or luxurious lifestyle.                         authorized representative in writing. Examples of reasons for us 
                                                                     not to accept an offer include, but are not limited to:
What forms do taxpayers need?                                          The taxpayer does not meet the requirements of New York 
  Form DTF-4.1, Offer in Compromise (For Fixed and Final             State Tax Law.
 Liability), or Form DTF-4, Offer in Compromise (For Liabilities       The taxpayer submitted false or misleading information.
 Not Fixed and Final and Subject to Administrative Review)             The taxpayer failed to make a full financial disclosure.
  Form DTF-5, Statement of Financial Condition and Other              There is evidence that after the taxpayer learned of the 
 Information, including copies of:                                    liability, some of the taxpayer’s assets were transferred.
 •  the last three federal income tax returns                          The taxpayer shows lack of a good faith effort to repay the 
 •  a credit report less than 30 days old                             liability.
 •  the last 12 months of statements from a bank or financial          The liability directly relates to a crime for which the taxpayer 
 institution                                                          pleaded or was found guilty.



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Page 2 of 2 Publication 220 (12/16)

  Accepting the offer would undermine voluntary tax                  Law summaries for offers in compromise
 compliance.
                                                                      Liabilities fixed and final (Tax Law section 171.15th)
  Accepting the offer would not be in the best interests of the 
 state.                                                               Further administrative and judicial review is not available 
                                                                      for liabilities under this subdivision. We may consider offers 
Under the following circumstances, the taxpayer may ask us to         from taxpayers that were discharged from bankruptcy, that 
reconsider the offer:                                                 are insolvent, or (for individual taxpayers only) for whom 
  There is a material change in the circumstances.                   collection in full would cause undue economic hardship. Use 
                                                                      Form DTF-4.1, Offer in Compromise (For Fixed and Final 
  We misinterpreted some of the information supplied.
                                                                      Liability).
  The taxpayer substantially increases the amount originally 
 offered.                                                             Liabilities still subject to administrative review (Tax Law 
                                                                      section 171.18th-a)
What if a taxpayer can’t fulfill the offer?                           In addition to the grounds considered in section 171.15th, 
If a taxpayer fails to meet all the terms and conditions of the       we may consider an offer if there is doubt about the 
offer in compromise, the offer is in default. We will give the        taxpayer’s liability for the taxes due. Use Form DTF-4, Offer 
taxpayer a chance to remedy the default. If the taxpayer fails to     in Compromise (For Liabilities Not Fixed and Subject to 
do so, we will revoke the offer and reinstate the original liability, Administrative Review).
including all interest and penalties, minus any payments made.
                                                                      Certain joint personal income tax liabilities (Tax Law 
What if two taxpayers have joint income tax                           section 171.18th-d)
liabilities?                                                          To make an offer under this subdivision, taxpayers must have a 
If two taxpayers have joint income tax liabilities, each may make     liability on a previously-filed joint income tax return. They must 
an offer together on one DTF 4.1 or DTF-4, or each may make a         also, at the time of the offer, be separated from their spouse 
separate offer. If we accept only one of the two offers, once that    under a decree of divorce or separate maintenance, or a written 
taxpayer pays we forgive further payment only for that taxpayer.      separation agreement, or a judicial decree of separation, or 
The other taxpayer continues to be liable for the remaining           living apart and not considered married under Internal Revenue 
balance and subject to collection.                                    Code section 7703(b). Also, collecting a spouse’s share of the 
                                                                      liability from a taxpayer (within a reasonable period) would 
                                                                      impose substantial economic hardship on the taxpayer. Use 
What if a taxpayer owes trust taxes?                                  Form DTF 4.2, Compromise of Spousal Share of Liability on 
Trust taxes currently include only withholding tax and sales tax.     Joint Tax Return.
We normally do not accept offers for less than the amount of the 
trust tax owed (not including penalties and interest). However, 
taxpayers wishing to make such an offer should include a              More information
statement of the reasons, along with any supporting documents.        This publication is intended only as an overview of the offer 
We will consider whether the business is still in operation,          in compromise process. For specific details, see 20 NYCRR 
whether the trust taxes were actually collected, and determine if     Parts 5000 and 5005 Compromises regulations.
the offer is in the best interest of all parties concerned.           For questions, call (518) 591-5000. For forms and more 
                                                                      information, see www.tax.ny.gov. Also, you can view all your 
What if a taxpayer is assessed as a responsible                       unpaid liabilities on your Online Services account. If you do not 
person?                                                               have an Online Services account, you can visit www.tax.ny.gov 
A taxpayer assessed as a responsible person liable for                and create one.
collecting and paying trust taxes for a business may make 
an offer in compromise for their liabilities, separate from the 
business. Any or all of the responsible persons may make an 
individual offer, and we will make a separate determination for 
each.
If we accept a responsible person’s offer, their payments reduce 
the business’s liability by that same amount. However, after 
they have made full payment, the liability of the business and 
of any other responsible persons remains open and collectible, 
reduced by the amount of the payments already made.
If a business applies for an offer in compromise and the 
responsible person does not apply individually, our accepting 
the business’s offer has no effect on a responsible person’s 
liability, other than reducing their liability by the amount paid by 
the business.

What if a taxpayer also makes an offer to the 
IRS?
New York State’s program operates independently from similar 
programs offered by the IRS, and the guidelines for accepting 
offers may differ. However, when applying for the state program, 
as part of the application a taxpayer may include a copy of the 
collection information statement given to the IRS.






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