Tax Lawyer's Blog

WebCPA reports that Joe Francis of “Girls Gone Wild” fame has filed a lawsuit against the IRS for illegal collection activities (emphasis added):
[S]hortly after the judge accepted his plea deal, the IRS filed a lien for $33,819,087.14 for three years of back taxes, from 2001 to 2003 (see IRS Files $34M Lien Against ‘Girls Gone Wild’ [...]

Bookmark & Share:

[Read more →]

California Tax Attorney Mitchell Port writes about the IRS’s post-appeals mediation and arbitration programs (Fast Track Settlement Pilot Program) for Offers in Compromise and the assessments of Trust Fund Recovery Penalties:
Under these two alternative dispute resolution programs, the taxpayer or Appeals may request nonbinding mediation. The taxpayer may decline Appeals’ request for mediation. Appeals will evaluate a [...]

Bookmark & Share:

[Read more →]

Audit reconsideration (PDF) is a procedure designed to help taxpayers who disagree with the results of:

1. An assessment IRS made because of an audit of your tax return; or
2. A return IRS created for you (Substitute For Return – SFR) because you did not file a tax return.
The Audit Reconsideration process allows the IRS to [...]

Bookmark & Share:

[Read more →]

Gregory H. Haubrich v. Commissioner of Internal Revenue – The taxpayer, Haubrich, filed a form 12153 Request for a Collection Hearing,  requesting, among other things, that the IRS enter into an Installment Agreement with him for the payment of back taxes in lieu of pursuing enforced collection.
The IRS appeals officer assigned to handle the request [...]

Bookmark & Share:

[Read more →]

If you disagree with an IRS action or determination, you generally have the right to have it reviewed by an IRS appeals officer.
The IRS is quite good at granting taxpayers their appeals rights.
The classic appeals case is when a taxpayer does not agree with an IRS auditor’s proposed adjustments to his tax return.
This post addresses [...]

Bookmark & Share:

[Read more →]