NAEA and the National Tax Practice Institute

I am fortunate that the National Association of Enrolled Agents has invited me to their annual Tax Institute on August 9 -11, 2009 in Baltimore, Md.
Here are the outlines for the topics I will be speaking on:
IRS collections
Tax bankruptcy
Trust fund recovery penalty
For more information on the NAEA and the National Tax Practice Institute, visit their [...]

I owe back taxes to the IRS. Now what? Part I of II

Every IRS problem has a solution.  Some solutions are quick.  Other workouts require more creativity, planning and patience.  When meeting with a client  - or during an initial telephone consultation – I like to discuss the following options and how each might fit in towards the ultimate goal of a fresh start:
1.   Offer [...]

Who do you pay first – IRS debt vs. credit cards?

It is not unusual for my clients to find themselves indebted to two masters – the IRS and credit card companies.  Both want a piece of the pie, but there is not enough to go around.  So who do you pay first? How do you make both go away?
The IRS comes first.  Here’s why:
1.   [...]

Bankruptcy as leverage in an offer in compromise

On more than one occasion I have used the possibility of bankruptcy as leverage in reducing the value of a offer in compromise.  The possibility of bankruptcy can have a big impact on an IRS compromise. 
Here’s why:
1.     A Chapter 7 bankruptcy can “discharge” a tax liability.  
2.     Any taxes that could be discharged by a potential [...]

Can I make the IRS an offer to pay tax only?

I received this question about using an offer in compromise on interest and penalties:
I owe $25,000 in tax, but the interest and penalties have made the amount I owe almost double.  Won’t the IRS be happy just to get the principal I owe back and forgive the interest and penalties?
In an offer in compromise, the [...]

Why a tax lawyer can make a difference

I am often asked by new clients how a tax lawyer can make a difference in an IRS dispute.  Here is my answer:

Once you retain a tax lawyer, the IRS must stop calling you.  The IRS is required to conduct all negotiations – telephone calls, meetings, etc. – through your attorney.  This valuable “buffer” allows [...]

Tough economy + aggressive IRS = tax bankruptcy.

All recent indications are that the IRS is plowing ahead in its collection efforts under a weakening economy.  Revenue Officers continue to push hard, and there are no signs that Automated Collection Service has backed off its levy and lien filings.
The unfortunate result of this pressure is that more and more clients are turning to a [...]

Offer in compromise vs. bankruptcy – Which settlement amount will be the lowest?

With new clients, I spend time discussing the options for obtaining a fresh start from IRS problems. The consultation most always involves making the client aware of the pros and cons of resolution by compromise, and by bankruptcy.  
In that spirit, here then is the first of a continuing series on the use of an offer [...]

How can an extension to file a tax return impact a discharge of taxes in bankruptcy?

One rule to follow in bankrupting income taxes is that the liability must be from a return that was due to be filed three years before the bankruptcy is commenced. The key is to be careful to include extensions of time to file in calculating the due date of the return, especially starting in 2009.   
Until [...]

When is the IRS prohibited from taking collection action? Part II

Here are five more situations in which the IRS is barred from taking collection action against you:

When the timeframe to collect the liability has expired.  The IRS has 10 years to collect a liability from the date it puts the liability on its books. When the 10 years is up, the tax is cleared from [...]

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