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Income Taxes › Tax Liens

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Rivkin Radler LLP

Collecting an Individual’s Unpaid Taxes from Their Controlled Entities

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An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more

Foodman CPAs & Advisors

¿Puedes Apelar Al IRS?

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Los contribuyentes tienen derecho a apelar al IRS. Entender cómo apelar al IRS es fundamental y los contribuyentes deben considerar contratar representación para disminuir los riesgos de litigio. Sólo los abogados, contadores...more

Foodman CPAs & Advisors

Can You Appeal The IRS?

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Taxpayers have the right to appeal the IRS. Understanding how to appeal the IRS is critical and Taxpayers ought to consider retaining representation in order to diminish the risks of litigation. Only attorneys, certified...more

Venable LLP

Taxpayers and Tax Preparers, Beware of Automated Notices of Deficiency

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The IRS has increased its practice to issue Notices of Deficiency without an audit. For example, if there is a mismatch between what was reported on a Form 1099 for a taxpayer and the income shown on the taxpayer's return, or...more

Freeman Law

Tax Court in Brief | Belton v. Comm'r | Seriously Delinquent Tax Debt” and IRS Requirement to Comply with Lien Procedure

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Summary: Petitioners, Willard Belton and Martha-Alexander Belton (Petitioners or Beltons) seeks review pursuant to section 7345(e), challenging the IRS’s certification to the Secretary of State that Petitioners had a...more

Freeman Law

Tax Court in Brief | Adams v. Comm’r | “Seriously Delinquent Tax Debt” and Passport Revocation

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Summary: Petitioner, Blake M. Adams, seeks review pursuant to section 7345(e) of the IRS’s certification to the Secretary of State that Adams has a “seriously delinquent tax debt” related to tax years 2007, 2009, 2010, 2011,...more

Freeman Law

Tax Court in Brief | Mattson v. Comm’r | Passport Revocation Notice for “Seriously Delinquent Tax Debt”; Limitations on Tax Liens

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Tax Litigation: The Week of December 5th, 2022, through December 9th, 2022 - Mattson v. Comm’r, T.C. Memo. 2022-118 | December 6, 2022 |Copeland, J. |Docket No. 16982-18P - Summary: Eric Mattson did not file income tax...more

Freeman Law

TIGTA Finds IRS Is Not Always Following Procedures for Tax Liens

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In 2021, the Internal Revenue Service filed 212,251 Notices of Federal Tax Lien (“NFTLs”). To provide perspective, in 2019 (i.e., pre-COVID-19 pandemic), the IRS filed 543,604 NFTLs. The IRS is working on ramping up its...more

Freeman Law

Tax Court in Brief | Goddard v. Comm'r | Collection Due Process, Penalties for Failure to Register a Tax Shelter

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Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Vorreyer v. Comm’r / Thoma v. Comm’r / Dowson v. Comm’r, T.C. Memo 2022-97| September 21, 2022 | Greaves, Judge | Dkt. Nos. (Consolidated)...more

Freeman Law

Tax Court in Brief | Kelly v. Commissioner | First-Time Abatement, Failure to File, and Failed Leniency

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Tax Litigation: The Week of July 11th, 2022, through July 15th, 2022 Colbert v Commissioner, T.C. Memo. 2022-74 | July 13, 2022 |Wells, J.| Dkt. No. 8395-16. Knight v. Comm’r, T.C. Memo. 2022-76| July 14, 2022 | Lauber, A. |...more

Freeman Law

Tax Court in Brief | Kotrides v. Commissioner | Collection Due Process, Abuse of Discretion, and Summary Judgment

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Tax Litigation: The Week of June 27th, 2022, through July 1st, 2022 Serna v Commissioner, T.C. Memo. 2022-66 | June 27, 2022 | Urda, J.| Dkt. No. 13202-19L Pedersen v. Commissioner, T.C. Summary Opinion 2022-11 | June 28,...more

Freeman Law

You Received an IRS CP504 Notice, Now What?

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The IRS sends a CP504 Notice when a taxpayer has failed to pay a balance owed. The CP504 Notice is a Notice of Intent to Levy issued pursuant to Section 6331(d) of the Internal Revenue Code. If a taxpayer fails to make...more

Freeman Law

The IRS and Nominee Liability

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Under the Internal Revenue Code, the IRS can satisfy a tax deficiency by imposing a lien on any “property” or “rights to property” belonging to the taxpayer.  The statutory language is broad and reaches virtually every...more

Freeman Law

Tax Court in Brief | Hamilton v. Comm’r | Collection Due Process and Abuse of Discretion

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Tax Litigation:  The Week of March 14, 2022, through March 18, 2022 AptarGroup, Inc. v. Comm’r, 158 T.C. No. 4 | March 16, 2022 |Goeke, J. | Dkt. No. 7218-2 Pickens Decorative Stone, LLC v. Comm’r, T.C. Memo. 2022-22 | March...more

Freeman Law

Tax Court in Brief January 31 – February 4, 2022

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Freeman Law

The IRS, Fraudulent Transfers, and Transferee Liability

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Can you be held liable for a tax liability owed by another taxpayer?  Yes, under certain circumstances.  The IRS  uses fraudulent transfer law and “transferee” liability tools to collect unpaid taxes where a taxpayer has...more

Freeman Law

Can You Transfer Assets to Avoid Paying Taxes to the IRS?

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In many cases, taxpayers attempt to transfer assets or property to third persons to shield those assets and property from the federal tax lien or federal tax levy. Predictably, the IRS has various tools at their disposal to...more

Freeman Law

The Tax Court in Brief - August 2021 #2

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 2 – August 6, 2021 - Belair v. Comm’r, Bench Opinion|...more

Freeman Law

The Tax Court in Brief - February 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of January 25 – January 29, 2021 - Costello v. Comm’r, T.C....more

Rosenberg Martin Greenberg LLP

IRS Highlights New Policies to Aid Those with Existing Tax Debts

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Changes Include Beneficial Payment Plan Options, Less Financial Disclosure for Many with Balances Due, and Ability to Delay Collection Actions - This has been a difficult year for many American taxpayers. In recognition...more

Freeman Law

A Fresh Start for Taxpayers: The Offer in Compromise

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IRS debt can be a life-changing burden.  But for some taxpayers, an offer in compromise may be an avenue to get rid of that tax debt and to receive a fresh start.  When a taxpayer qualifies for an offer in compromise, the IRS...more

Freeman Law

IRS Seizures: The Good, the Bad, and the Ugly

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Along with tax penalties and tax lien filings, the IRS’s ability to seize a taxpayer’s property is one of its most potent weapons to encourage tax compliance.  That is, in part, what makes a recent report from the Treasury...more

Maynard Nexsen

Letters and Notices from the IRS are Coming – What You Need to Know

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Given the recent expiration of the IRS’s People First Initiative on July 15, the return of IRS employees to offices and service centers, and this news release reminding taxpayers that collection activities would start...more

Burr & Forman

IRS Extends Streamlined Payment Plan Pilot Program Through September

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The IRS recently announced that it will be extending the streamlined payment plan pilot program through September 30, 2018. The plan allows taxpayers with federal tax liabilities up to $100,000 to qualify for streamlined...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

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There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

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