An offer in compromise allows you to settle your tax debt for less than the full amount you owe. It may be a legitimate option if you can't pay your full tax liability, or doing so creates a financial hardship. We consider your unique set of facts and circumstances:
Ability to pay; Income; Expenses; and Asset equity. We generally approve an offer in compromise when the amount offered represents the most we can expect to collect within a reasonable period of time.
In summation regardless of any debt owed (Del penalties all of them) the negotiated terms per. -IRS-mediator is based on said above and enforceability-reasonableness much less than what Del wants.