IRS Issues Guidance Regarding Levy Actions Involving Restaurant Revitalization Fund

The American Rescue Plan Act established the Restaurant Revitalization Fund (RRF) to provide support to eligible entities that suffered revenue losses related to the COVID-19 pandemic. Specifically, the U.S. Small Business Administration (SBA) will provide restaurants and other eligible entities with funding equal to their COVID-19 pandemic-related revenue loss up to $10 million per business [...]

What To Do if I Can’t Pay My Taxes by the IRS’s July 15 Tax Deadline

            In light of the current Covid-19 pandemic, the Internal Revenue Service (IRS) extended the April 15, 2020, filing and payment deadlines for federal individual income taxes for the 2019 tax year to July 15, 2020. Due to the pandemic, many taxpayers are finding themselves in difficult financial circumstances. They are unable to pay their [...]

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, [...]

Can the IRS Can Foreclose on My Home?

Yes. If you owe money to the Internal Revenue Service (IRS), the IRS has many tools it may use to collect that money, including foreclosure action against your home. This is usually a tool of last resort for the IRS. The IRS will generally take many other steps to try to collect the outstanding federal [...]

Can The IRS Really Seize My Assets Without Telling Me First?

The Internal Revenue Service (IRS) can utilize its jeopardy levy function (i.e., taking a taxpayer’s assets) to pursue a taxpayer’s assets prior to issuing a jeopardy assessment (i.e., telling a taxpayer how much they owe). In Chief Counsel Advice (CCA) 201830013, the IRS clarified the circumstances in which it would take such drastic steps. In [...]

How Does an Employer Comply with an IRS Wage Levy?

When an individual has outstanding federal tax liabilities, the Internal Revenue Service (IRS) has a number of tools at its disposal to try to collect the liabilities from the individual, including levying the individual’s wages (I.R.C. § 6331(a)). When the IRS issues a wage levy notice to an employer, the employer must pay the IRS [...]

Are Sexual Harassment Settlement Payments and Attorney Fees Tax Deductible?

Are Sexual Harassment Settlement Payments and Attorney Fees Tax Deductible? It depends on whether the business requires a nondisclosure agreement as part of the settlement. Previously, under IRC §162, businesses were allowed a deduction for amounts paid in connection with a legal settlement pursuant to employee complaints such as discrimination and sexual harassment. However, Section [...]

The Jeopardy Levy: Understanding the IRS’s Most Dangerous Levy Action

In certain instances, the IRS can issue a jeopardy levy to seize available assets without the taxpayer’s knowledge. The IRS does not use this form of enforced collection action often but, when the IRS uses it, the consequences can be devastating. In most instances, prior to proceeding with levy action, the Internal Revenue Service (IRS) [...]

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