Howard Levy is a Cincinnati tax attorney with the experience to find solutions to your IRS problems.

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NAEA and the National Tax Practice Institute

By Howard S. Levy, Esq., Bankruptcy and the IRS, IRS Collection Problems, Trust fund recovery penalty

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 website at www.naea.org. ... Read More

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

By Howard S. Levy, Esq., Bankruptcy - Chapter 13, Bankruptcy - Chapter 7, Bankruptcy and the IRS, Currently Not Collectible, Interest and penalties, Offer in compromise

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 in compromise.  This is the first option on every one's mind.  But it can be difficult to obtain an compromise under current IRS procedures - it is not for everyone.  Many compromises are initially rejected by the IRS and have to be appealed.  And with IRS expense allowances ... Read More

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

By Howard S. Levy, Esq., Bankruptcy and the IRS, Currently Not Collectible, Installment agreements, Interest and penalties, Statute of limitations on collections

In addition to (1) offers in compromise, (2) bankruptcy and (3) uncollectible (See Part I, above), here are three more solutions to owing back taxes to the IRS: 4.      Statute of limitations on collection.  The IRS has 10 years to collect unpaid taxes - starting from when the IRS puts the tax liability on its books (this is usually when a tax return is filed or an audit is completed). The limitations period is is the ultimate ace in the hole and is not to be squandered - there is an end date to your IRS problem.  Getting there requires properly calculating the end date and navigating ... Read More

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

By Howard S. Levy, Esq., Bankruptcy - Chapter 13, Bankruptcy - Chapter 7, Bankruptcy and the IRS, Interest and penalties

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.     Unpaid credit cards can be annoying - harassing debt collectors calling for money.  But it is important to remember that credit card companies and debt collectors cannot take your wages, bank accounts or property.  That can only be done by the filing of a lawsuit, which the debt collector cannot do (they are not ... Read More

Bankruptcy as leverage in an offer in compromise

By Howard S. Levy, Esq., Bankruptcy - Chapter 7, Bankruptcy and the IRS, 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 offer in compromise. Here's why: 1.     A Chapter 7 bankruptcy can "discharge" a tax liability. 2.     Any taxes that could be discharged by a potential bankruptcy cannot be collected against the future income of the taxpayer. 3.      A critical component of an offer in compromise is an IRS calculation of how much can be collected from future income. 4.     If bankruptcy is "Plan B" to an ... Read More

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Howard S. Levy

A former IRS trial attorney, Howard Levy has over 20 years of experience representing individuals and companies facing tax controversies.

IRS Practice Areas

  • Automated Collection Service
    (48)
  • Bankruptcy and the IRS
    (39)
  • Criminal investigation
    (10)
  • Currently Not Collectible
    (24)
  • Economic hardship and the IRS
    (17)
  • Employment taxes
    (19)
  • Innocent spouse
    (9)
  • Installment agreements
    (34)
  • Interest and penalties
    (13)
  • IRS Audits
    (29)
  • IRS collection notices
    (30)
  • IRS Financial Statements
    (37)
  • IRS levies and property seizures
    (67)
  • Offer in compromise
    (61)
  • Revenue Officers
    (44)
  • Statute of limitations on collections
    (30)
  • Tax Court
    (17)
  • Tax liens
    (8)
  • Trust fund recovery penalty
    (21)
  • Unfiled returns
    (26)

Learn the Basics

When do I know it’s right to file an offer in compromise? 5 top reasons.

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What to expect when an IRS Revenue Officer comes calling to your home or business.

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Is there such a thing as a hardship status with the IRS?

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Defaulted on your IRS installment agreement? Where do you turn now?

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Will bankruptcy help in getting the IRS to release a levy or seizure?

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