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A Year in Review: TTB Offer-in-Compromises for 2024

Writer's picture: James NiekampJames Niekamp

The Alcohol and Tobacco Tax and Trade Bureau’s (TTB) offer-in-compromise (OIC) data for 2024 reflects a notable increase in both median and average percentages of liability paid in compromises compared to recent years. While these figures highlight a shift, they are not entirely without precedent.


For 2024, the median percentage of liability accepted via OIC reached 47.25%, which is a bit higher than the 31.66% median in 2023 and 27.93% in 2022. This marks a return to levels seen in 2021 (53.23%) and 2019 (46.18%), which also featured relatively high median values.


Over the past decade, median percentages have fluctuated, with years such as 2015 and 2017 hitting lows of 11%, contrasted by 2021, which had the highest median acceptance rate of the past decade at 53.23%.


The average percentage of liability paid for 2024 stands at 43.65%, also reflecting an increase from 39.38% in 2023 and 37.59% in 2022.  Similar to the median trend, this figure aligns closely with 2019 (45.26%) and 2021 (47.98%), indicating that 2024’s numbers are high, but not historically unique.


These shifts in compromise percentages could indicate evolving enforcement priorities or changing patterns in taxpayer behavior. The return to higher median and average percentages suggests a more stringent acceptance process for offers or an increased emphasis on recovering larger portions of outstanding liabilities.


Overall, 2024’s data places it among the higher tiers of the last decade, signaling a continued commitment by the TTB to ensure compliance while providing pathways for resolution.


A summary of OIC acceptance rates by year, broken down by median and average, is provided below. This summary only covers data going back to 2014, however a more comprehensive archive of previously accepted OIC data can be found on TTB's website.


Year

OIC Acceptance % (Median)

2014

28%

2015

11%

2016

17%

2017

11%

2018

23%

2019

46%

2020

37%

2021

53%

2022

28%

2023

32%

2024

47%

Year

OIC Acceptance % (Average)

2014

30%

2015

23%

2016

21%

2017

17%

2018

24%

2019

45%

2020

39%

2021

48%

2022

38%

2023

39%

2024

44%




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