Our income tax laws can be complex when applied to unique or varying fact patterns. This can result in tax liabilities. Tax liabilities can also arise when someone legitimately owest tax and simply does not pay it. There are various collection remedies available for tax liabilities. These remedies often have the best outcome when there……
Tag: Tax Procedure
COVID-19 Extended Tax Deadlines Longer Than Many Realized
Taxpayers have various tax filing deadlines throughout the year. Missing one can trigger penalties, interest charges, and collection actions. When there is a major disaster, the IRS typically grants short extensions to give affected taxpayers breathing room. During the COVID-19 pandemic, the IRS issued notices extending various tax deadlines by a few months. The agency……
Installment Agreements Can Extend the IRS Collection Deadline
The IRS has ten years to collect unpaid taxes after assessment. But that deadline isn’t always final. Those with unpaid tax debts often seek payment plans to be able to pay their tax liabilities over time. When a taxpayer requests or enters into an IRS installment agreement, the clock on the collection statute stops running.……
Qualified Offer Delivery: “Addressed To” vs “Delivered To”
You’ve done everything right in working with the IRS and the IRS still got it wrong. You’ve exhausted your administrative remedies and you have to hire a tax attorney. Now you are incurring costs just to correct the IRS error. The attorney has you make a proper qualified offer under Section 7430(g) to recover attorneys……
Can the IRS Require Personal Information for a Business Tax Debt?
You have a business entity. You took the time to form it. You made all of the tax filings. And then the business can’t pay its own tax liabilities. It owes the IRS back taxes. As you try to work with the IRS to resolve the balance, the IRS wants to know about your personal……
The IRS Collection System is Broken
Taxpayers sometimes owe the IRS and cannot currently pay. It happens. When it happens, taxpayers often reach out to the IRS for help. The IRS has processes in place to handle these requests. In fact, it has a while collection function that is set up to handle these requests. This collection function is a bureaucratic……
You Can’t Raise What You Didn’t Know: The Variance Doctrine
Our income tax system uses a self-reporting process. Taxpayers, in most cases, voluntarily file income tax returns. The IRS can then evaluate the filings to determine whether they appear to be correct or warrant further investigation. The IRS has developed a whole regime of forms to be used for this very purpose. Taxpayers who fill……
Can Jury Trial for IRS Penalty be Conditioned on Paying the Penalty First?
There have been a number of court cases that have considered whether various administrative agency determinations violate constitutional jury trial rights. These are often premised on the fundamental promise of American justice that courts should remain open to all. The issue is presented when government agencies require substantial upfront payments before allowing judicial review. One……
Business Owner Liable for Tax Incurred by a Buyer After the Sale of the Business?
If you own a business and you sell it to a third party, should you be liable to the IRS for taxes triggered by the buyer after the business you sold? What if the tax was triggered by the buyer’s wrongdoing? What if there was no evidence that you even knew that the buyer would……