News & Analysis as of

Internal Revenue Service Debt Collection

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
McGlinchey Stafford

Litigation Byte (June Edition)

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The Litigation Byte is the new name and format for McGlinchey’s Commercial Law Bulletin. Our new format reflects McGlinchey’s national coverage and our expanded footprint while still serving up the digestible, insightful...more

Foodman CPAs & Advisors

Ofrecimiento De Transacción: Oportunidad Para Resolver La Deuda Tributaria

El IRS emitió el Consejo Fiscal 2024-37, el 24 de abril de 2024, para informar a los contribuyentes que no pueden pagar su deuda tributaria completa o si pagar les causaría dificultades financieras, que deberían considerar...more

Foodman CPAs & Advisors

Offer In Compromise: Opportunity To Solve Tax Debt

IRS issued Tax Tip 2024-37, April 24, 2024, to inform taxpayers that can’t pay their full tax debt or if paying would cause financial hardship, that they should consider applying for an offer in compromise which is a program...more

Foodman CPAs & Advisors

¿Puedes Apelar Al IRS?

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?

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

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

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Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

Foodman CPAs & Advisors

Contribuyentes De Altos Ingresos Cuidado Que Las Acciones Del IRS Se Intensifican Si No Se Presentan Declaraciones De Impuestos

El 2/29/24, el IRS anunció un nuevo esfuerzo centrado en los contribuyentes de altos ingresos que no han presentado declaraciones de impuestos federales sobre la renta en más de 125,000 casos desde 2017. Los envíos por correo...more

Foodman CPAs & Advisors

High-Income Taxpayers Beware That IRS Actions Escalate If Tax Returns Aren’t Filed

On 2/29/24, the IRS announced a new effort focused on high-income taxpayers who have failed to file federal income tax returns in more than 125,000 instances since 2017. The mailings include more than 25,000 to those with...more

Gray Reed

When is an Accountant Forced to Testify Against Their Client?

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Recently, in a criminal case involving a physician who hired an accountant to prepare and submit certain tax forms to the IRS on her behalf, the court denied attorney-client and work-product privilege claims and ordered the...more

Lerch, Early & Brewer

IRS Levy Allowed on Classic Italian Cello to Satisfy Outstanding Estate Tax Liabilities

Lerch, Early & Brewer on

United States v. Firestone - In United States v. Firestone, the United States (Government or U.S.) sought to enforce a judgment against Defendant Omar Firestone (Omar) for outstanding tax liabilities related to the Estate of...more

Kohrman Jackson & Krantz LLP

Move Over TikTok, the Tax Man May Be Snooping on You, Too

In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...more

Rivkin Radler LLP

Supreme Court Upholds IRS Collections Summons Without Notice

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The Supremes- The Constitution has figured prominently in the news of late. In the days preceding the initial discussions among members of the Administration and the Congressional leadership regarding the debt ceiling,...more

Foodman CPAs & Advisors

Programa De Pasaportes Del IRS Continúa

El IRS había suspendido ciertas actividades de cobro, incluyendo la certificación de pasaportes en respuesta a la pandemia de COVID-19; sin embargo, desde 2021, el IRS retomó su proceso de certificación de pasaportes ante el...more

Foodman CPAs & Advisors

IRS Passport Program Continues

The IRS had suspended certain collection activities including passport certification in response to the COVID-19 pandemic; however, since 2021, the IRS resumed its passport certification process to the U.S. Department of...more

McDermott Will & Emery

Tax Court Holds That Deficiency Petition 90-Day Time Limit Is Jurisdictional

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Last summer, the Supreme Court of the United States held that the 30-day time limit to file a Collection Due Process (CDP) petition is a non-jurisdictional deadline subject to equitable tolling (Boechler, P.C. v....more

Gerald Nowotny - Law Office of Gerald R....

Ten Years After - The IRS Collection Statute of Limitations

I was a youngster for the Woodstock Music and Art Fair commonly known as Woodstock took place in Bethel, NY between August 15-18, 1969. Frankly, I never knew anyone growing up in the Canal Zone that attended in person. The...more

Gerald Nowotny - Law Office of Gerald R....

The Letter

Overview - Most of you know that I am a big music fan. I have always liked Joe Cocker. The song The Letter is a song that was originally performed by The Box Tops and was a Number 1 hit in 1967. The song was covered by Joe...more

McDermott Will & Emery

Weekly IRS Roundup September 12 – September 16, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 12, 2022 – September 16, 2022...more

Freeman Law

Tax Court in Brief | Chinweze v. Commissioner | Collection Due Process and IRS Form 3877 Mailing Requirements

Freeman Law on

Tax Litigation: The Week of June 6th, 2022, through June 10th, 2022 Musselwhite v. Commissioner, T.C. Memo. 2022-57 | June 8, 2022 | Ashford, J.| Dkt. No. 14380-16 Spencer v Commissioner, T.C. Memo. 2022-8 | June 7, 2022 |...more

McDermott Will & Emery

Late CDP Petitions May Still Be Entitled to Tax Court Review

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In a unanimous decision in Boechler, P.C. v. Commissioner issued on April 21, 2022, the Supreme Court of the United States reversed the US Court of Appeals for the Eighth Circuit’s ruling (which affirmed the US Tax Court) and...more

Gray Reed

Negotiating with the IRS Collection Division

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Once the IRS makes an assessment against a taxpayer, the taxpayer will receive several notices before the IRS takes enforced collection action....more

Troutman Pepper

1099C Language in Collection Letters: Third Circuit District Court Grants Defendants’ Motion for Summary Judgment in FDCPA Case

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In Bordeaux v. LTD Fin. Servs., L.P., a Third Circuit district court granted summary judgment to the defendants in a Fair Debt Collection Practices Act (FDCPA) case. In its holding, the court emphasized Third Circuit...more

McDermott Will & Emery

Weekly IRS Roundup November 2 – November 6, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 2, 2020 – November 6, 2020... November 2, 2020: The IRS announced COVID-19-related...more

Rosenberg Martin Greenberg LLP

IRS Highlights New Policies to Aid Those with Existing Tax Debts

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

Foodman CPAs & Advisors

What do you do if you are a Financial Institution with COVID-19 Loan Accommodations near the end?

On August 3, 2020, the Federal Financial Institutions Examination Council (FFIEC)  issued a Joint Statement on Additional Loan Accommodations Related to COVID-19 regarding loans  that are near the end of an initial loan...more

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