Deadlines are a central feature of our tax system. We have written about many of these various deadlines on this website. From deadlines for filing returns, deadlines for various tax elections, to deadlines for filing appeals from audits, to deadlines for filing collection actions, deadlines for appeling IRS audits, and even tax court and other……
Tag: Tax Procedure
When Providing Information to the IRS Discloses Additional Tax Due
The IRS consumes information about taxpayers. By and large, that is what the IRS is–a vacuum for information. It then processes the information and applies statutorily mandated processes to evaluate the information. The processes are geared toward evaluating whether additional tax is owed and then recording that balance on the IRS’s books, so that the……
Can a Tax Attorney Recover Attorney’s Fees from the IRS for their Own Case?
The IRS administrative process is intended to catch incorrect tax returns and make adjustments to fix the returns. This includes false and fraudulent tax returns as well as those with honest errors. This includes an IRS audit function, and IRS appeals function, and IRS counsel function. And each step has a management oversight function and……
When Can the IRS Pursue a Deceased Spouse’s Estate Without Probate?
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……
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……