The “Process” of the IRS Appeals Collection Hearing

The government establishes processes to carry out its essential functions. These processes handle a myriad of different types of cases and cases with nuanced fact patterns. These processes allow the government to process a high volume of cases. They often do so in bulk. The process is a like well-trodden path. The path may take…

Married Filing Separate Spouse Liable for Tax

Marriage, Divorce & Taxes

Marriage presents a number of difficult tax questions. One question is whether both spouses can be held liable when they file separately and one spouse fails to pay their taxes. This is a common marriage tax question that we are asked. One might think that the married filing separate status fully protects the other spouse.…

When Withdrawing IRS Tax Lien Facilitates Collection

The IRS’s collection efforts can impact different taxpayers differently. While the IRS has broad collection powers, there are some taxpayers who are largely immune from the IRS’s collection efforts. This varied impact is partly due to the range of collection tools Congress has provided to the IRS. The IRS lien notice provides an example. Many…

The IRS “Effective Tax Administration” Settlement

Life has a way of getting in the way. Whether it is a health issue, a financial setback, or some other circumstance. The IRS often finds itself having to contend with these situations experienced by taxpayers. This often comes up when there are back taxes. Or when the life issue results in back taxes. Taxpayers…

IRS Offer In Compromise: The Deemed Acceptance Rules

The IRS has missed just about every deadline in the past few years. Most of the IRS’s employees have basically been on paid vacation for the past few years. When Covid-19 first emerged, IRS employees were sent home. They were paid not to work. While private-sector employees scrambled to find ways to work, many IRS…

Contesting the IRS’s Passport Certification for Back Taxes

The IRS has a lot of tools available to help it collect unpaid taxes. This includes liens, levies, and even seizing property. Congress added the ability for the IRS to certify passports for those who owe back taxes and have refused to pay. Congress provided a judicial remedy for erroneous certifications. There have not been…