How to Appeal the Trust Fund Recovery Penalty After the Appeal Period has Passed: Offer in Compromise, Doubt as to Liability

There are many reasons businesses fall behind on paying their federal tax liabilities. Falling behind on certain kinds of taxes, sometimes called “trust fund” taxes, may result in the IRS assessing those taxes against the business owners, officers, or other individuals the IRS considers to be “responsible” for ensuring the payment of those taxes.  Federal [...]

IRS Taxpayer Roadmap

The Internal Revenue Service (IRS) Taxpayer Advocate Service (TAS) recently released the above “subway map” to illustrate, at a very high level, the stages of a taxpayer’s journey through the tax system. The map provides a high level overview of the processes for tax return preparation, tax return processing, notices from the IRS, audits, appeals, [...]

IRS Announces Increase to Late Filing Penalties for 2018 Federal Tax Returns

The IRS recently announced that taxpayers who owe tax and did not file their 2018 returns before Friday, June 14, 2019 will be subject to increased late filing penalties.  penalty kicks in. The failure-to-file penalty is assessed if there is unpaid tax and the taxpayer fails to file a tax return or request an extension [...]

Taking Advantage Of Expanded Penalty Relief

The recent enactment of the Tax Cut and Jobs Act (TCJA) put many individual taxpayers in a difficult position regarding their estimated tax obligations for the 2018 tax year. Fortunately, the Internal Revenue Service (IRS) released Information Release and Notice (IR) 2019-55 expanding the guidance for penalty relief relating to the underpayment of individual income [...]

Claim for Refund of the Trust Fund Recovery Penalty

An individual assessed the Trust Fund Recovery Penalty (TFRP) has the option to pay just a portion of the assessment to gain access to a court. This is different from the requirement for income taxes, which calls for payment, in full, of the tax, penalty, and interest, before a court can hear the case. The [...]

IRS Clarifies Innocent Spouse Statute of Limitations

In a previous blog article, we addressed the courts invalidating the Internal Revenue Service’s (IRS’s) two-year statute of limitations for claiming innocent spouse relief pursuant to IRC Section 6015(f). Subsequently, the IRS issued interim guidance and stopped enforcing the two-statute of limitations for these claims. On August 12, 2013, the IRS issued proposed Treasury Regulations [...]

The Potential Problems Taxpayers Face When Waiting Until the Last Minute to Timely File Amended Returns

Waiting until the last minute is nearly always a bad strategy. This is certainly true in tax preparation, whether it is preparing an original or amended tax return. For taxpayers seeking a refund from an amended return, in particular, there are potentially very serious problems for those who wait until the last minute to file. [...]

Can I Recover Income Tax Refunds When I File My Returns Late?

Many individuals and businesses fail to file their income tax returns for multiple years for a variety of reasons, usually stemming from life and business pressures that made it almost impossible for them to file their returns. When they finally have the time and motivation to prepare and file the returns, they realize that they [...]

Filing a Claim for Refund of Federal Taxes

Sometimes a situation arises when a taxpayer overpays his or her taxes for a particular year. When a taxpayer overpays his or her taxes, he or she can file a Claim for Refund to recover the amount of the overpayment. One common example of a Claim for Refund is when a taxpayer files his or [...]

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