All kinds of penalties are being assessed by the Internal Revenue Service (IRS) against taxpayers, and more can be expected in the future. In 1954 there were 13 penalties in the Internal Revenue Code, and now there are more...more
Once the IRS makes an assessment against a taxpayer, the taxpayer will receive several notices before the IRS takes enforced collection action....more
12/17/2021
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Tax Returns
When a tax return has been selected for office examination, generally the examination of the return will be conducted at the office of the IRS. Normally a taxpayer will find an office examination has begun when he or she has...more
There is a wealth of information available from the IRS that is not generally made available to the public. Most of this information can be obtained by asking. ...more
Many people end up owing the IRS for many reasons and there are various options to resolve your tax debt. Some of the options include an offer in compromise, installment agreement, or currently non-collectible status....more
What is the Statute of Limitations? -
The Internal Revenue Code limits the time in which the government may assess tax. There are two civil statutes of limitations. The first is the period during which the IRS can assess...more
An assessment results when the liability of a taxpayer is recorded in the office of the Secretary of the Treasury. The assessment establishes the right of the IRS to collect the tax. ...more
There is a general misconception about what the IRS can and cannot do. Owing money to the IRS is not like owing any other creditor. The IRS is one of only a few creditors who can seize and sell your home even though state...more
Once a taxpayer overpays a tax, it is necessary to file a claim for refund before any action can be undertaken to seek a refund of such tax from the government. The purpose of the claim for refund is to place the IRS on...more
Lawyers, tax or otherwise, understand that privileged information must be protected to encourage a full and frank dialogue that might not occur without confidentiality.1 Tax information, in particular, contains some of the...more
Field examinations involve returns with more complex issues, thereby requiring examination by someone more knowledgeable in the field of accounting and the Internal Revenue laws. Field examinations are conducted by Revenue...more
While dealing with the IRS generally involves submitting documents or legal authority to support a client’s position, in most cases the element of negotiating is present. Negotiating becomes particularly important in dealing...more
Understanding the IRS and the tax laws is very difficult and confusing. When a taxpayer has a tax controversy matter with the IRS, selecting a tax attorney may be just as confusing and complicated. Not all attorneys are...more
Litigation in all forms is becoming extremely expensive to clients. This is not only because of legal fees, but also because of the penalties and interest that continue to accrue when dealing with the IRS. A taxpayer has...more
Overview of the Appeals Process -
The goal of the Appeals Office is to settle as many cases as possible within the broad guidelines of its Mission Statement...more
If you haven’t read Part 1 of this blogpost, you might appreciate the background in that post. That post dealt primarily with the concepts of communication during the audit....more
Dealing with the Internal Revenue Service (IRS) is sometimes a difficult and complicated process. Even more so now given the pandemic. Interactions with a Revenue Agent may not happen in person, but there will be contact...more