TC 780: Offer in Compromise Accepted

What the code actually does

TC 780 records acceptance. IRM 5.19.7.2.6 names it in exactly those terms — "TC 780 = Accepted" — as one of the three transactions that close out a pending offer and end the collection statute suspension the pending code started.

IRS Document 6209, Section 8A sets its preconditions: "to post, a return (TC 150) and an unreversed TC 480 must be posted." So it cannot appear on a module that never carried a pending offer, and it cannot appear on a year with no return. Where a client believes a year was included in an accepted offer and no acceptance code appears on it, that is a real discrepancy worth chasing rather than a display quirk.

Interest and failure-to-pay stop computing

Doc 6209 records this in both master files. On business accounts the posting "prevents computer calculation of interest and FTP"; on individual accounts it "prevents computer generation of credit or debit interest."

This is the mechanical expression of what acceptance means: the compromised amount is now the amount, and the module stops growing. For a client who has watched a balance accrue for years, it is the most tangible thing the acceptance does, and it happens automatically rather than on request.

It also means that a module still accruing after an apparent acceptance is showing something wrong. Either the code has not posted to that period, or the interest was restricted and is being computed manually — both worth identifying before a client is told the balance is fixed.

The stopping of the clock is also what makes the acceptance date worth recording precisely. IRM 5.19.7.3.2 records that the code “uploads to IDRS systemically using this acceptance date when the AOIC record changes to a monitoring status,” so an error in that date propagates to every module in the offer, and correcting it afterwards requires the transaction to be reversed and manually re-input rather than simply amended.

The eight-week refund freeze catches clients out

Doc 6209 states it precisely: "credits are frozen from refunding in all tax modules of the account for 8 weeks; also, credits in the affected tax module are frozen from offsetting in or out."

Two things there are worth separating. The eight-week freeze reaches every module in the account, not only the compromised years — so an unrelated refund the client was expecting will not arrive on schedule. And the freeze on offsetting in or out applies to the compromised module specifically.

A client who has just had an offer accepted and then finds a refund missing will reasonably assume something has gone wrong with the agreement. Telling them about the eight weeks in advance is a small piece of client management that prevents a genuinely worrying phone call. It sits alongside the separate rule that refunds for the year the offer is accepted are generally kept by the Service under the offer’s own terms, which is a different point and a more permanent one.

What TC 780 gets confused with

It gets confused with the completion code. TC 788 is not this code’s reversal and does not undo it — Doc 6209 requires "an unreversed TC 780 must be posted" before a TC 788 can post at all, which makes the completion code dependent on this one rather than opposed to it. Acceptance and completion are separated by the whole term of the offer.

It gets confused with the end of the matter. Acceptance starts a compliance period during which the terms have to be met; the real reversals are the default and termination codes, and either can put the original liability back. A practitioner should be as attentive to the years after acceptance as to the ones before it.

And it gets confused with TC 480, the pending code, particularly by clients reporting what they were told on the phone. A pending offer and an accepted offer are separated by the entire investigation, and the two codes are the only reliable way to tell which one a client is actually in. Where the calculation of what should have been offered is still live, the OIC pre-qualifier works from the same financial standards the Service applies.

The practitioner’s actual next step

Confirm the acceptance posted to every period the offer covered, since the IRM contemplates manual input "to each applicable tax period" when the systemic upload fails.

Check that interest and failure-to-pay have actually stopped on each of those modules, and investigate any that are still accruing.

Warn the client about the eight-week refund freeze across the whole account before they notice it themselves.

Diarise the compliance period, because the codes that undo this one are the ones that matter next.

Do not read the completion code as a reversal, and do not expect it for years.

Read the acceptance against the pending posting and its date with the IRS Transcript Decoder, since that pair is what establishes how long the collection statute was suspended.