1. Filing an Offer in Compromise (OIC) on a 941 debt of an Open Corporation - Why is this a bad idea? First, because the IRS doesn't really accept these, except in the rarest of situations. You are frankly better off at closing the corporation and seeing if the debt goes to the grave with the old corporation.
2. Focusing on an Offer (OIC) over Currently Not Collectible -- Salespeople tend to get obsessed with the Offer in Compromise program as do their advertisements. ("Settle your Debt!") Often, getting a debt placed in Uncollectible Status is BETTER than doing an Offer as you don't have to pay the IRS anything! Offers are NOT easy to get. U. Status is easier.
3. Talking about a Penalty Abatement when the Taxpayer doesn't qualify (yet) -- Remember: the only way you are going to get penalties off is if you demonstrate to the IRS that you are NOW a good taxpayer. If you aren't filing on time or paying on time, put the penalty abatement off until you are current.