An amount = to the taxpayers assets (quick sale valve, less liens and less exemptions)
An amount they could receive from taxpayer’s earnings over 48 months (if cash offers) or 60 months (if a short-term deferred other possible over 24 months)
DOUBT AS TO LIABILITY (USED OCCASIONALLY)
Client takes the position that the tax is not actually owed.EXAMPLE: Client fails to exhaust administrative remedies and the tax assessed against him has become FINAL.*NOT necessary to file a collection information statement with offer.
EFFECTIVE TAX ADMINISTRATION (RARELY USED)
The tax is technically collectible, but would create an value hardship on the taxpayers; ex: elderly person with medical problems despite having paid home.