Resolving IRS Taxes: What is “Future Income”?

When it comes to tax rules and government administrative guidance, one may expect that the provisions are clear and can be easily applied. However, this is often not the case. Even detailed regulations with explanations may fail to provide readily discernible answers. Applying such rules to common situations can still lead to questionable or incorrect…

Settling Back Taxes for a Probate Estate

Executors who administer probate estates often have to deal with back taxes that the decedent owed. They may also have to deal with estate tax liabilities owed by the estate. While the probate process is governed by state law, state law gives way to Federal law when it comes to back taxes. The IRS has…

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…

IRS Collectors Influence on Settlemet Offer

The IRS makes decisions about tax returns, back taxes, etc. These decisions may be made by one or more persons within the IRS. These decisions may be made by IRS employees whose job functions and missions are not the same. This is most evident in the context of IRS audits. The IRS auditor’s mission is…

Tax Debts & the Dreaded Dissipated Asset

It is very difficult to run a business and to do so in full compliance with all of our laws. Having worked with thousands of business owners, the message is the same. Something always seems to give. If the business focuses on the operational side of the business to comply with industry regulations or to…

Offer in Compromise Extends IRS Collection Time

When you owe the IRS back taxes, sometimes it is best to simply wait for the IRS’s collection statute to expire. This wait-and-see approach involves waiting to see if the IRS attempts to collect the tax debt. Sometimes the IRS doesn’t even bother to take any action to collect unpaid taxes. To succeed, it is…

Discharging Taxes in Bankruptcy vs. Settling with the IRS

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…

Informal Offer in Compromise? Is There Such a Thing?

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.…

How the IRS Evaluates Offer in Compromise

In Zumo v. Commissioner, T.C. Summary Opinion 2013-66, the U.S. Tax Court examined a case involving the Internal Revenue Service’s (“IRS”) rejection of an offer in compromise based on doubt as to collectibility. An offer in compromise is a request by a taxpayer to settle their tax debt for an amount that is less than…