• “PART PAY” INSTALLMENT AGREEMENTS

    The continuing hostility of the IRS bureaucracy toward offers in compromise, and the recent decision of the Congress to severely restrict the avail­ability and usefulness of bankruptcy, may combine to place more emphasis on installment agreements. But some taxpayers, particu­larly those with large tax debts involving multiple tax years, may find that they can’t meet […]

  • NEGOTIATING INSTALLMENT AGREEMENTS

    Written for the Maryland Society of Accountants One of the tasks most frequently faced in representing clients before the IRS Collection Division is negotiating an “installment agreement” — an arrangement under which the taxpayer makes monthly payments against the outstanding tax debt, free of the threat of levy and distraint action. Despite the Service’s imposition […]

  • NEGOTIATING OFFERS IN COMPROMISE

    The last article in this series on dealing with the Collection Division addressed Installment Agreements — arrangements through which tax debts can be resolved by means of monthly payments. Some folks, however, owe so much that an installment agreement is not a practical solution. Interest and penalties can accrue so quickly that the liability actually […]

  • TARA REVISITED – THE NEW “INNOCENT SPOUSE ” RULES

    Scarlett: But Rhett darling, our Separation Agreement requires you to pay any taxes resulting from the IRS audit that was going on during our divorce. Now Revenue Officer Sherman has levied my wages and seized my horse and my last mint julep! Rhett: Frankly, my dear, I don’t give a damn. Sound familiar? Ever represent […]

  • THE NEW “INNOCENT SPOUSE ” RULES

    Scarlett: But Rhett darling, our Separation Agreement requires you to pay any taxes resulting from the IRS audit that was going on during our divorce. Now Revenue Officer Sherman has levied my wages and seized my horse and my last mint julep! Rhett: Frankly, my dear, I don’t give a damn. Sound familiar? Ever represent […]

  • FEDERAL TAX LIENS – Part I

    The federal tax lien is at the heart of all enforced collection action taken by the IRS Collection Division. Accordingly, representing clients requires an understanding of how the lien arises, the kinds of property to which it attaches, the consequences of such attachment, the duration of the lien, the priority of the tax lien over […]

  • FEDERAL TAX LIENS – Part II

    This is the second part of a two-part article about the federal tax lien. The last article covered the nature of the lien, focusing primarily on its broad reach, attaching as it does to “all property and rights to property” of the taxpayer wherever situated. In the paragraphs below, we will consider the priority of […]

  • THE STATUTE OF LIMITATIONS ON COLLECTION

    For those beleaguered souls for whom nothing else works, the only hope of relief from unmanageable federal tax debts may be the statute of limitations on collection. In theory, the IRS has only 10 years from the date of assessment to collect. However, this 10-year limitation is shot through with so many exceptions, waivers and […]

  • HEALING SELF-INFLICTED WOUNDS – REPRESENTING NONFILERS

    Never do today what you can put off until tomorrow . . . All of us procrastinate. But some take things to dangerous extremes — putting off the filing of tax returns for a few years, or even many years. The IRS estimates that each year some ten million people fail to file their tax […]

  • THE TRUST FUND RECOVERY PENALTY

    The road to Hell, so we’re told, is paved with good intentions. And on the road to Hell, failure to pay employment taxes is definitely the fast lane. The resulting “trust fund recovery penalty” can spell disaster for the hard-pressed entrepreneur, corporate manager, director, officer, or employee who falls victim to it. This article will […]