IRS Law Blog

IRS Revenue Officers are the most experienced and sophisticated collection employees within the IRS. They work high dollar cases identified by the IRS to be of significance.  Focus is often given to business cases, employment tax liabilities,...

In these difficult economic times, repaying the IRS is becoming harder than ever. Installment agreements may be entered into in good faith, but while payments are being made, interest and penalties continue to run. Every...

Here is a reason to always file your tax returns… I just resolved a case where my clients did not file their 2000 and 2001 returns. This resulted in the IRS making an estimate of...

For taxpayers seeking to contact the IRS on their own, what follows is a reason not to go at it alone but through a tax professional. Professionals can access the IRS Automated Collection Service by first...

I received this question from a reader about a closed business that owes employment taxes to the IRS, and her personal liability for the taxes: The IRS is trying to collect on employment taxes from...

Today’s Cincinnati Enquirer published an editorial of mine about offering IRS amnesty to non-filers. There are 6.1 million non-filers – to find out how to bring them back into the system with a fresh start and stimulate...

When negotiating with IRS Revenue Officers, it is important to remember the many enforcement tools they have at their disposal.  These powers include: 1.     Filing a Federal tax lien securing the IRS’s interest...

Internal Revenue Code section 6334(a) shields certain taxpayer assets from the IRS collection powers.  As these assets are beyond the reach of the IRS, it is important to remember to always exclude their value from...

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,...

The IRS cannot take collection action against the separate income of a non-liable spouse. If separate tax returns are filed, only the person who signed and filed the return is legally obligated to pay the taxes....

If you cannot pay your delinquent taxes because of an economic hardship, the IRS can suspend collection efforts against you.  This does not mean your debt is forgiven; just that the IRS will defer collection...

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...

Entrepreneurs justifiably take great pride in their business.  But this pride often gets in the way of a clear understanding of the risk of continuing to operate into a storm of IRS trouble.  The IRS...

There are limits on the IRS continuing audits year after year.  These audits are known as “repetitive audits.” Their scope is limited by Internal Revenue Manual 4.10.2.8.5. The Internal Revenue Manual states that if you...

Here are the final five situations to look for when the IRS cannot take collection action: When the value of the property is protected by exemptions provided by Section 6334 of the Internal Revenue Code....

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...

The list of when the IRS cannot take property is fairly extensive, so I will do this in parts to break it down simply. Here is Part I of when the IRS is prohibited from...