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.…
Category: Offer in Compromise
Offer in Compromise
A settlement option that allows taxpayers to pay less than the full amount owed to satisfy their tax debts. Give us a call to see how we can help, (713) 909-4906.
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…
Household Expense Rules for IRS Offers in Compromise
The IRS has broad discretion to settle unpaid taxes. It can compromise taxes for any amount and for any reason–even for no reason. Absent the IRS dropping the ball, the IRS set up a very specific process and rules that it applies in deciding to compromise tax debts. This is the IRS’s offer in compromise…
Offer in Compromise: Documenting the Value of Assets
The IRS has a structured process for settling tax debts. This is handled through the IRS’s ‘offer in compromise’ program. The program itself has several different sections or workstreams. The primary workstream is the ‘doubt as to collectiblty’ workstream. This refers to offers that are submitted by taxpayers based on their inability to pay. Assuming…
Navigating IRS Collections During an Economic Downturn
The financial downturn has left many taxpayers struggling with unpaid tax debts just as IRS collection efforts ramped up. Though a challenging time, the economic turmoil also created opportunities to negotiate with the IRS from a position of strength. Negotiating with the IRS is always challenging. But with proper diligence and records, taxpayers can use…
Offer in Compromise Deemed Accepted by the IRS
The IRS consumes volumes of information. It processes this information largely by processing paper forms. This includes paper forms submitted by you, the taxpayer and your tax attorneys, and by internal forms created by IRS employees. This inefficient paper form submission and processing is complemented by an insistence on sending taxpayer notices by mail. The…
The Impact of IRS Inefficiency on Tax Collections
The IRS has a reputation for being relentless when it comes to collecting taxes. However, what happens when the agency fails to do its job in a timely manner? What happens when the IRS delays working on cases? Can the IRS benefit from delaying the collection of taxes and denying taxpayer claims? Can the IRS…
New Offer in Compromise Legislation
As discussed in a previous post, Congress has been toying with making changes to the IRS offer-in-compromise program. These changes were eventually included in the “Tax Increase Prevention and Reconciliation Act,” which President Bush signed into law on May 17, 2006. The new rules apply to offers in compromise filed 60 days after the date…
Congress Changes the IRS Offer in Compromise
The IRS offer in compromise (“OIC”) program is a tax resolution option offered by the IRS to help taxpayers who are unable to pay their full tax liability. It allows eligible taxpayers to settle their tax debts for less than the full amount owed, based on their financial situation and ability to pay. The OIC…
The Three Offer in Compromise Options
The IRS Offer in Compromise program presents taxpayers with a viable option to settle tax debts for an amount less than what is owed. The program has been around for quite some time and, as with everything when it comes to the IRS, there are a number of nuances. The IRS has developed numerous procedures…