IRS Law Blog

United States Tax Court is a specialized court that exclusively handles matters related to certain tax issues. At the most basic level, the Tax Court is not an Article III court. Instead, it is a...

An IRS Notice of Determination can be a frustrating experience. You were working things out with an IRS Settlement Officer when you hit a fork in the road. You believed that they were not allowing...

What’s the benefit of negotiating with a Settlement Officer? Sometimes, when negotiating with the IRS collection division, results can be based not only on the strength of your case, but also on who you talk...

A certified mail slip comes in the mail, with a notation a letter awaits from you from the IRS, likely from the IRS Automated Collection Service. Or maybe an IRS Revenue Officer makes an unannounced...

The ability to file a collection due process appeal is probably the most powerful right you have in defending against IRS enforcement by levy or seizure. Due process, in the context of IRS collections, means...

“How long does the IRS usually take to investigate an offer in compromise?” is a great question, and one I am often asked by clients. The answer is six to twelve months, on average, although...

If you owe the IRS back taxes, it is not always enough to just be “right” when negotiating with the government. You need to be right, but you also need to be in the right place...

In most every case, the IRS cannot take your property until they send you a letter stating their intentions.  This letter – called a “Final Notice of Intent to Levy” – is the government’s last attempt to reach you...

“I know I filed it, but the IRS tells me they never received it.” Tax returns – lost.  Collection appeals – misplaced.  Innocent spouse claims – never processed. The reality is that the IRS does...

The IRS has updated its handbook on Collection Due Process appeals (Chief Counsel Notice 2009-10). Included in the handbook is internal IRS guidance on issues such as disqualified employment tax levies, levies on single member limited...