IRS Law Blog

If you find yourself in an IRS pickle, there are three IRS employees you are most likely to come face to face with.  Those are Revenue Officers, Revenue Agents and Special Agents.  Here is what...

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,...

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...

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...

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...

Since I often help clients close out IRS audits when their records are lacking, I thought it was time to answer this question: I recieved a letter to meet an auditor from the IRS to...

IRS Revenue Officers continue to become more aggressive in the field. Here is a new approach to look for: I had a recent case in which a Revenue Officer sent my client a notice stating...

Tax Court judges have experience either as former government lawyers or in the private sector at law firms. Of the thirty-two Tax Court judges, thirteen previously worked for the government as IRS lawyers; four were...

I received this referral this week about eliminating taxes in bankruptcy: I was audited for my 2005 taxes and owe $55,000 to the IRS as a result.  I owe other debt in addition to the...

I hear this often when I suggest bankruptcy as a source of resolution.  I heard it again today during a telephone conversation with a new client.  Here is what I explained to the client: Under the bankruptcy code,...

This is frustrating, and has happened to my clients in the past. The IRS does not want the compromise to default any more than you do. The IRS wants to give you an opportunity to...

I just settled an audit on behalf of a client that had to make its way to Tax Court to be resolved.  The audit was caused by significant losses my client claimed on rental real...