IRS Law Blog

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...

I often have clients who are very focused on an offer in compromise.  But before we plunge in, the first thing I do is check on how much longer the IRS has to collect the...

A common question about the impact of an IRS levy on a bank account: I just looked up my bank account balance, and saw that the IRS sent a levy to my bank.  The bank...

I recieved a good question about how the IRS applies payments on employment tax liabilities.  The question was in response to my article and recent post about IRS trust fund investigations. This is important. If a...

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...

In addition to offers in compromise, bankruptcy, and uncollectible (See Part I, above), here are three more solutions to owing back taxes to the IRS: Statute of limitations on collection. The IRS has 10 years to...

In today’s difficult economic environment, expect more businesses to resort to using payroll tax money to stay afloat and a corresponding increase in IRS enforcement measures. With bank lending tight, employee tax withholding is a...

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...

The IRS appears to be human, and it makes legal and administrative errors when seizing property, says the Treasury Inspector General for Tax Administration (TIGTA). TIGTA just completed a review of 50 IRS property seizures...

I have seen a stream of new calls from readers who went through an IRS audit and are receiving IRS collection notices for amounts they probably do not owe. Although they disagreed with the audit,...

It is always important to understand what the IRS is asking, and why. Resolution of most collection cases involves providing answers to IRS questions about you.  The questions are asked on an IRS financial statement,...

The IRS is hiring revenue agents (auditors), revenue officers (collectors), and special agents (criminal investigators).  This has been made public by the IRS, but I attended a joint conference with the IRS last week in...

A common problem with IRS audits is not seeing eye to eye with the auditor. The auditor sees the case narrowly, while you see the big picture.  You know you incurred that expense or did...

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 offer in...

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...

It really does happen – you can overturn an IRS audit in Tax Court. My client disagreed with an IRS audit that determined she should pay a 10% tax on early distributions from her retirement...

House Ways and Means Oversight Committe Chairperson Charles Lewis and Ranking Member Charles Boustany have introduced H.R. 2343, the Tax Compromise Improvement Act of 2009. The bill would eliminate the requirement of IRC 7122(c) that...