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IRS Debts Offer in Compromise Tax Procedure

Forgotten Offer in Compromise Extended IRS Collection Time

Sometimes it is best to wait for the IRS’s collection statute to expire. This is a wait-and-see approach where the taxpayer waits to see if the IRS attempts to collect the tax debt. To succeed, it is important for the taxpayer to not extend the IRS’s collection statute. This issue came to a head in […]

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IRS Debts Tax Procedure

Finding Opportunities to Contest Tax Liabilities

Opportunities for Contest Tax Liabilities – Houston Tax Attorney The IRS puts taxpayers on notice by mailing letters and notices. It is common for these letters and notices to not be delivered or to be delivered late. This can present a serious problem for taxpayers, particularly when the letter or notice is one that proposes […]

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Bankruptcy Tax IRS Debts Offer in Compromise Tax Procedure

Discharging Taxes in Bankruptcy vs. Settling with the IRS

Bankruptcy can be one of the best methods for resolving tax debts. This is particularly true if the taxpayer’s primary assets only consist of retirement accounts and equity in a personal residence. The recent In re Moore, No. 15-42046 (Bankr. E.D. Tex. Jul. 7, 2016), case presents an opportunity to consider the results if the […]

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IRS Debts Tax Procedure

IRS Collections When Taxpayer’s Income Varies

In Charnas v. Commissioner, T.C. Memo. 2015-153, the U.S. Tax Court addressed whether a lawyer who had variable income from year to year was able to pay his outstanding tax debt. The court concluded that the IRS erred in not considering the variable nature of the taxpayer’s income in determining whether he could pay his […]

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Installment Agreement IRS Debts IRS Liens & Levies Tax Procedure

Court Says Tax Lien Does Not Have to Be Filed Prior to Entering Into an Installment Agreement

In Budish v. Commissioner, T.C. Memo. 2014-239, the U.S. Tax Court held that the IRS erred in insisting on a tax lien being filed before it would accept an installment agreement. This case serves as a reminder that a tax lien does not have to be filed if it creates a hardship that would make […]

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IRS Debts Offer in Compromise Tax Procedure

Informal Offer in Compromise? Is There Such a Thing?

What if you reach an oral agreement with the IRS to settle the tax debt, but then the IRS back tracks on the agreement? If you didn’t submit the offer on a Form 656, do you have any rights? The court addresses this in Bergdale v. Commissioner, T.C. Memo. 2014-152. Facts & Procedural History Mr. […]

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IRS Debts Offer in Compromise Tax Procedure

Example of How the IRS Evaluates Offer in Compromise for Doubt as to Collectibility

In Zumo v. Commissioner, T.C. Summary Opinion 2013-66, the U.S. Tax Court concluded that the IRS was correct in rejecting an offer in compromise based on doubt as to collectibility. The case provides a good overview of the IRS collection process and how the IRS evaluates offers in compromise. Facts & Procedural History Dr. Zumo […]