656-L

Offer in Compromise Doubt as to Liability (DATL)

Agency
IRS
Revision
Rev. 7-2026
Fillable fields
117
Pages
10
Official source
IRS form page
Checked
October 21, 2026
Fill 656-L online
Page 1 of form 656-L

Form 656-L: Offer in Compromise (Doubt as to Liability)

Form 656-L is the IRS form for an offer in compromise based on doubt as to liability (DATL). The About Form 656 page describes an offer in compromise as an agreement with the IRS that settles tax liabilities for less than the full amount owed. The instructions in the PDF say DATL "exists where there is a genuine dispute as to the existence of or the amount of the correct tax debt under the law."

The PDF holds its own instructions, a DATL pre-qualifier assessment with 11 questions, the form itself in Sections 1 to 8, a Privacy Act statement and an application checklist. The instructions say a DATL offer cannot be considered if the liability has been established by a final court decision or judgment, or if the assessed tax is based on current law. For a tax debt that is agreed but cannot be paid in full, the instructions point to Form 656 in the Form 656-B booklet instead.

You can fill out Form 656-L free in your browser on this page and download it without an account.

What's on Form 656-L

DATL pre-qualifier assessment

Eleven yes or no questions. A yes to any of questions 1 to 10 points to another route, such as an amended return, audit reconsideration, a CP2000 response or penalty relief.

Section 1: Individual Information

Names, SSN or ITIN, physical and mailing addresses, an EIN for self-employed individuals, and tax periods for Form 1040, 941, 940, the Trust Fund Recovery Penalty and other federal taxes.

Section 2: Business Information

Business name, physical and mailing addresses, EIN, the name, title and phone of a primary contact, and tax periods for Form 1120, 941, 940 and other federal taxes.

Sections 3 and 4: offer amount and terms

Section 3 holds the amount offered. Section 4 lists terms a) to q), covering payments, levies, the extension of the assessment period, the 24-month rule, tax liens and secure messaging.

Section 5: Explanation of Circumstances

Marked "THIS SECTION MUST BE COMPLETED." It holds the explanation of why the tax is believed to be incorrect, with room to attach more sheets.

Sections 6 to 8: signatures and preparers

Signatures of the taxpayer and the spouse or authorized corporate officer, voice mail consent boxes, details of anyone else who prepared the application, and a paid preparer section with CAF number or PTIN.

How to fill out Form 656-L

  1. 1

    Run the pre-qualifier

    Answer the 11 questions. The form says a taxpayer who answered no to questions 1 to 10 may qualify to file a DATL offer, and that without a tax debt there is no offer until a balance due notice is received.

  2. 2

    Section 1 or Section 2

    Enter the identifying information and list every tax period the offer covers. If more space is needed, the form says to use a separate sheet titled "Attachment to Form 656-L Dated" with the date, signed and dated after the list.

  3. 3

    Section 3: the offer

    Enter the amount believed owed. The checklist says the offer has to be $1.00 or more and that an offer of $0 is returned without further consideration. No payment goes with the form.

  4. 4

    Section 5: explain and document

    Explain why the tax is believed to be incorrect. The instructions ask for a written statement plus supporting documentation, and say to put the name and SSN, EIN or ITIN on every extra sheet.

  5. 5

    Section 6: sign

    Sign, date and add a daytime phone number. On a joint offer the spouse also signs, and for a business an authorized corporate officer signs. A box allows the IRS to leave detailed voice mail messages.

  6. 6

    Sections 7 and 8

    Fill in Section 7 if someone other than the taxpayer prepared the application, and a paid preparer completes Section 8. For a representative, include Form 2848 or 8821, or a copy of one already filed.

Why fill Form 656-L on indox

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Where it goes, fees and what happens next

Where to mail

The checklist gives Brookhaven Internal Revenue Service, DATL Unit, P.O. Box 9008, Stop 681-D, Holtsville, NY 11742-9008.

No fee or payment

The checklist says there is no application fee or payment required for a Doubt as to Liability offer. The instructions say payments received will not be returned and will be applied to the tax liability.

Not together with Form 656

The instructions say a DATL offer and a separate DATC offer on Form 656 cannot be submitted at the same time. If both are sent, the DATC offer is returned without further consideration.

24-month rule

Term m) says the offer will be accepted by law unless the IRS gives written notice otherwise within 24 months of the date the IRS centralized offer in compromise unit in Brookhaven, NY received it.

Collection while the offer is pending

The terms say the IRS may file a Notice of Federal Tax Lien during consideration, may levy until an IRS official signs the offer as pending, and extends the assessment period while the offer is pending plus one year if it is rejected, returned, terminated or withdrawn.

Returned offers

The instructions say an offer without a written explanation and supporting documentation of why all or part of the tax debt is incorrect is returned without further consideration.

Who files Form 656-L?

  • Individuals (Form 1040 filers)

    Section 1 is for individuals, with a line for a spouse on a joint offer and an employer identification number line for self-employed individuals only.

  • Businesses

    Section 2 is for businesses that file Forms 1120, 940, 941 and similar returns, with the business name, EIN and a primary contact.

  • Responsible persons for the Trust Fund Recovery Penalty

    Section 1 has a line for the Trust Fund Recovery Penalty as a responsible person of a named business, for withholding and Social Security taxes.

  • Preparers and representatives

    Section 7 names anyone else who prepared the application and Section 8 is for a paid preparer. The form says to include a signed Form 2848 or 8821 for someone to represent the taxpayer.

  • Not for inability to pay

    The instructions say a taxpayer who agrees the tax is owed but cannot afford to pay does not file Form 656-L and uses Form 656 from the Form 656-B booklet instead.

  • Cases the instructions exclude

    The instructions list cases that do not qualify, such as an open bankruptcy, restitution owed to the Department of Justice, or an accepted offer for the same tax year and liability.

The form is completed by or for the taxpayer who disputes a tax debt, and the package is mailed to the IRS DATL Unit listed on the form.

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Questions about Form 656-L

How is Form 656-L different from Form 656?

Form 656-L is for doubt as to liability, a dispute over whether a tax is owed or how much. The About Form 656 page says Form 656, in the Form 656-B booklet, is for offers based on doubt as to collectability or effective tax administration.

Is there an application fee for Form 656-L?

No. The checklist says there is no application fee or payment required for a Doubt as to Liability offer, and says not to send any payments with the offer.

What is the smallest amount that can be offered?

The instructions and checklist say $1.00 or more, and that an offer of $0 is returned. Section 3 of the form itself says the offer must be greater than $1.00.

Where is Form 656-L mailed?

To Brookhaven Internal Revenue Service, DATL Unit, P.O. Box 9008, Stop 681-D, Holtsville, NY 11742-9008, as printed on the form's checklist.

What goes in the package with the form?

The instructions ask for a written statement explaining why all or part of the tax debt is incorrect, plus supporting documentation or evidence. The checklist adds a Form 2848 or 8821 if a third party will represent the taxpayer.

Can a DATL offer be sent during an audit reconsideration?

The instructions say that if another IRS function, such as audit reconsideration, is addressing the liability, the taxpayer waits until that process is complete before submitting an offer.

How long does the IRS have to decide?

Term m) of the form says the offer will be accepted by law unless the IRS notifies the taxpayer otherwise in writing within 24 months of the date the offer was received.