Handcuffs over $100 bills and a yellow post it with the word Taxes written on it.

Anticipating Tax Litigators…And the IRS (Part 2 of 2): Tax Strategy Tips

Since the COVID-19 pandemic, the Internal Revenue Service (IRS) has had a long backlog that, due in part to funding received in the Inflation Reduction Act of 2022, it only began to catch up on in mid-2023. In the meantime, the IRS’s backlogs and delays might have lulled taxpayers into a false sense of security. [...]

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, [...]

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 [...]

Offer in Compromise – Is It An Option?

We regularly receive calls from people who tried to resolve their tax obligations through an Offer in Compromise, but the Offer was rejected. Some have submitted the Offer on their own and some have been represented by an accountant, CPA, or an attorney. The one thing all of these Offers had in common was that [...]

I Owe the IRS Money – What Can I Do?

We often receive telephone calls and e-mails from individuals and businesses who have been contacted by the IRS for a tax obligation owing and they don’t know what to do. There are many options for dealing with these obligations. The correct option depends on the facts of the case. Unfortunately, too often, an individual or [...]

Effective Tax Administration (ETA) Offer – An Underutilized Option.

In her annual Report to Congress, Nina Olson , the Taxpayer Advocate, pointed out that the IRS is under-utilizing the Effective Tax Administration (ETA) Offer in Compromise (OIC) program. The IRS accepted an average of only 27 ETA OICs per year. The ETA program is designed as an alternative to the Doubt as to Collectibility [...]

Can I challenge the Internal Revenue Service’s (IRS) decision to pursue me for unpaid taxes?

Yes. You have many options for challenging an IRS assessment. Two common procedures are the Collection Due Process (CDP) hearing and the Collections Appeal Program (CAP) hearing, depending on the circumstances. The CDP program gives you the right to appeal the filing of a Notice of Federal Tax Lien (IRC 6320) or the right to [...]

Can an In-Business Corporation Compromise its Employment Tax Obligations With The IRS?

Yes. An in-business corporation can compromise its outstanding employment tax obligations with the IRS. In past years, the IRS required that an Offer in Compromise (OIC) from an in-business corporation include not only its ability to pay, but also, the amount the IRS could collect from the responsible parties through the Trust Fund Recovery Penalty [...]

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