IRS Law Blog

Everyday, I see how the IRS is responding to people hurt by the economy. The Journal of Tax Practice and Procedure asked me to write an article about it  – “IRS Collections in Troubled Times.” Current...

The IRS is generally known to be prompt in processing offers in compromise. But the IRS is also known for losing files and not processing claims. Sometimes, things get washed into the big bureacracy. So,...

If you have had trouble paying taxes to the IRS in the past and would like to settle up, the first step is to ensure that you are paying your taxes now.  The IRS 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...

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...

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...

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...

In determining whether you can repay a delinquent tax liability, the IRS uses its own expense allowances to arrive at your cash flow.  Just because you have the expense does not mean the IRS will...

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,...

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...

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...

The IRS offer in compromise program has been promoted endlessly over the last several years. Turn on your television, open up the newspaper, or listen to the radio, and there it is. My clients usually...

I recently received a email question inquiring about how the IRS values retirement assets in an offer in compromise. If you do not have the right to access the retirement money, then neither does the...

In the vast majority of cases, you will not lose any of your stuff to the IRS.  Most clothing and personal household belongings are beyond the scope of the IRS collection power.  Here’s why: Section...

IRS enforced collection activity continues to heat up.  Compromise settlements are down by 70% while bad debt accounts continue to accumulate.  Here are the numbers: 1.     779,000 taxpayer accounts were assigned to the IRS collection queue. 2....