Podcasts about irs collection

Yes, the IRS makes your job hard. But knowing the ins and outs of IRS processes can actually make your firm more profitable AND sustainable. Business owners and taxpayers need help with tax representation. If you don't know how to resolve their case, you're leaving money on the table. Because what you're really resolving is STRESS – and your clients are willing to pay big for that.    In this episode, Dan Henn of Tax Resolution Academy joins ProMarketer Podcast host Christian Jones to talk about why tax representation services are key to growing your firm (without being chained to a desk).    Dan Henn teaches tax firm owners how to confidently take on IRS Exam and IRS Collection cases, with over three decades of expertise as an entrepreneur, tax education speaker, and author. His Fast Start Bootcamp offers 16 hours of CPE with the tools and resources you need to make tax resolution a powerful revenue generator for your firm.   Resources   https://taxresolutionacademy.com/   Fast Start Bootcamp: https://www.faststartbootcamp.com/fsbc-2025

The IRS suspended collections of IRS debt back in 2020. Now, they have started back up again. IRS expert Dan Pilla is here to tell you what you need to know.  

Joining Eric on this week's Tax Rep Network podcast is The IRS Director of Collection Policy, Rocco Steco, to update us on where the IRS is right now in terms of ramping up enforcement, when can we all expect the enforcement notices to start showing up, and the impact of the ERC credit processing freeze on collection cases.

Joining Eric on this week's Tax Rep Network podcast is The IRS Director of Collection Policy, Rocco Steco, to update us on where the IRS is right now in terms of ramping up enforcement, when can we all expect the enforcement notices to start showing up, and the impact of the ERC credit processing freeze on collection cases.

Due process is, according to Black's Law Dictionary, “a course of legal proceedings … which have been established … for the enforcement and protection of private rights.” Anyone facing an IRS federal tax lien or levy has already experienced the preliminary due process following the IRS determination that more taxes are owed.   Due process involves a series of written or telephone notifications, and it's all laid out in the tax code and the IRS letters the taxpayer receives in the mail that should definitely not be ignored. Before the IRS wrecking ball goes into motion, the taxpayer has certain procedural rights. In this presentation, I will discuss them in detail. --- Support this podcast: https://podcasters.spotify.com/pod/show/mike36/support

Episode 26:  In this episode, Timalyn explains what happens when the IRS pursues payment from you for back taxes.  She'll discuss some of your taxpayer rights, even when you're behind on your tax payments. Special Note:  This episode's launch will mark the podcast's 1-year anniversary.  Thank you for your continued interest and time. As we get started, please note the abbreviation CDP refers to Collection Due Process.  Timalyn may use this abbreviation throughout this episode. When You Can't Pay Your Taxes When this episode is released, the individual tax filing deadline will almost be here.  Unfortunately for many, the tax liability may be more than they have set aside to pay taxes.  People question whether they should file if they can't pay.  What will the IRS do if they don't pay?  Will they go to jail?  There are many reasons anxiety and stress begin to take over.  However, that's not the time to freeze and simply do nothing. Timalyn explains that the Taxpayer Bill of Rights ensures you have the right to due process when it comes to IRS collection enforcement. You have protections from asset seizure, such as your property or money in your bank account. IRS Collection Due Process Hearing Under this process, IRS collection actions that have occurred or have been proposed can be reviewed by way of an appeal.  For instance, if you've received a notice of a federal tax lien filing, you have a right to appeal it.  This also applies to a final notice (IRS notice of intent to levy). Taxpayer Appeals If you appeal an IRS action, the appeals process is handled by a department independent of the Internal Revenue Service collection department. It's meant to provide the taxpayer with a fair and objective review of the situation.  The objective is to ensure the IRS follows the rules. Remember, the IRS is authorized to levy your accounts.  Social Security recipients can actually have their monthly checks levied before they are deposited into the recipients' accounts.  The IRS can garnish wages.  Even though the IRS is a federal entity, it can grab your state tax refund, in addition to any federal tax refund you may be anticipating. Requesting a Collection Due Process Hearing In addition to the above situations, you also have other times during which you can request a CDP Hearing, as a taxpayer. ●      Have you received a Notice of Jeopardy Levy?  You have a right to appeal. ●      Have you received a Notice of Levy on your state tax refund?  You have the right to appeal. ●      Have you received any other form of IRS Levy?  Again, you have the right to appeal To request a hearing, IRS Form 12153 must be submitted by the taxpayer.  This is the Request for Collection Due Process Hearing or Equivalent.  It must be submitted within 30 days of the date on the notice, not the day you received it. How Many Times Can You Request a Hearing? Timalyn clarifies that you are eligible to request per tax period, per action.  For instance, if you've received a Notice of Intent to Levy after a Notice of Intent to issue a tax lien.  In other words, you can make 2 separate requests, for the same tax period.  Collection Statue Expiration Date Remember the IRS can collect on any tax debt up to 10 years from the date it was assessed.  The specific date that collection right expires changes if you request a hearing (i.e. make an appeal).  The IRS is unable to proceed while the appeal is being reviewed. However, the time the pause lasts will get added back onto the 10-year collections window, once the appeal has concluded.  For more information on this topic, refer to Episode 5 where Timalyn explains the Collection Statute Expiration Date (”CSED”). What Happens in a CDP Hearing? This is the opportunity for you, as a taxpayer, to tell your story.  Timalyn explains you are able to propose collection alternatives at the hearing.  It's a good tool for you to use. You'll need to be prepared.  This means having receipts and paperwork in order.  You may be able to propose an installment agreement, instead of having the levy imposed.  You could propose an offer in compromise and request the time required to submit the offer.  You could possibly propose you be placed in the Currently Not Collectible status.  What if I Don't Agree with the Decision of My CDP Appeal? Timalyn explains you still have another option.  You can appeal the decision in court.  Once again, this 2nd appeal will pause the collection enforcement.  However, as Timalyn discussed above, that time will be added back onto the 10-year window the IRS has to collect a tax debt. If you are going to submit the IRS Form 12153, be sure to send it to the address on the notice you received.  Equivalent Hearing If you decide to pursue your appeal, but you've exceeded the 30 days from the date on the notice you received, there's still an option.  You actually have 1 year from the date on the notice to request an equivalent hearing. The most significant difference between the Collection Due Process Hearing and the Equivalent Hearing is that you can't take the decision of the latter to court.  In Timalyn's experience, most people are able to reach some type of agreement during either of the hearings.    Does It Feel Too Complicated or Overwhelming? For some individuals, this can be a very intimidating situation.  It's understandable.  If this is you, remember, you also have the right to representation.  There are tax professionals who can represent you.  Check out Episode 23 for the full story.  In short, an enrolled agent (such as Timalyn) is licensed to represent taxpayers in all 50 states.  Certified Public Accountants (CPAs) and tax attorneys can also represent you. An EA (enrolled agent) or a CPA can represent you in the actual Collection Due Process hearing.  Understand that if you take your CDP appeal decision to court, you'll need a tax attorney to represent you in that venue.    Timalyn comments that her accounting firm, Bowens Tax Solutions, specializes in representing taxpayers at the CDP hearings.  They can actually handle this for you, so you don't have to appear at the hearing or equivalent. If you truly feel overwhelmed, you still have options.  Remember, back taxes shouldn't ruin your life. As we conclude Episode 26, we encourage you to connect with Timalyn on social media. You'll be able to subscribe to this podcast on Spotify, Apple Podcasts, Google Podcasts, and many other podcast platforms.   Remember, Timalyn Bowens is America's Favorite EA and she's here to fill the tax literacy gap, one taxpayer at a time.  Thanks for listening to today's episode. For more information about tax relief options, visit https://www.Bowenstaxsolutions.com/ . If you have any feedback, or suggestions for an upcoming episode topic, please submit them here:  https://www.americasfavoriteea.com/contact.   Disclaimer:  This podcast is for informational and educational purposes only.  It provides a framework and possible solutions for solving your tax problems, but it is not legally binding.  Please consult your tax professional regarding your specific tax situation.  

In this episode of Legal Thoughts, the attorney discusses the topic: " THE IRS COLLECTION PROCESS AND TAXPAYERS' OPTIONS". If you enjoy this podcast, make sure to stay tuned for more episodes from the taxation, litigation, and immigration Law Firm of Coleman Jackson, P.C. Be sure to subscribe, leave a comment, and rate our Legal Thoughts podcast on Apple Podcasts, Spotify, and Google Podcast. Visit the taxation, litigation, and immigration law firm of Coleman Jackson, P.C. online at www.cjacksonlaw.com

Welcome to the first episode of the IRS Whisperer podcast! In this episode, Dan discusses why you should consider writing a book to expand your marketing strategy and some great tips on how to get started. He also shares some important things to consider when collecting payments from clients before wrapping up with an introduction to handling IRS collection cases.   Key Takeaways: - How to incorporate a book into marketing your tax practice - 3 tips for sustaining a profitable tax practice - Why you might consider avoiding electronic signatures when handling IRS collection cases   The IRS Whisperer podcast is dedicated to helping you develop an efficient and profitable IRS Representation practice. Be sure to subscribe on your favorite podcast platform so you don't miss an episode.   Do you have some feedback or questions about this episode? Leave a note in the comment section or reach out on social media: Facebook: https://www.facebook.com/IRSWhisperer Instagram: https://www.instagram.com/irswhisperer/   Helpful Resources: - Notion - Project management and note-taking software: https://www.notion.so/ - CPACharge - provides CPAs with a simple, secure, and streamlined way to accept payments: https://www.cpacharge.com/ - TaxDome - Manage your firm & clients in one place: https://taxdome.com/   The IRS Whisperer is powered by the Tax Resolution Academy® - a digital community for tax pros seeking support, educational materials, and up-to-date instruction on IRS representation cases. Learn how to grow your firm, operate more efficiently and profitably, and provide the best possible representation to your clients. To learn more or join, go to https://community.taxresolutionacademy.com/ctr

Eric Green is a Tax Attorney, Author, and National Speaker on IRS Civil and Criminal Tax Problems. He is a frequent speaker on tax issues, such as tax audits and conflicts. Eric also hosts a weekly podcast called Tax Rep Network, available on all major podcasting platforms, including Apple Podcasts, iTunes, Spotify, etc. He is the author of the Accountant's Guide to IRS Collection and The Accountant's Guide to Resolving Tax Debts: Offers-in-Compromise, Installment Agreements, and Uncollectible Status. Eric earned a national reputation by negotiating favorable settlements in thousands of civil cases against government agencies. He has also persuaded government agents and attorneys to dismiss criminal charges and civilly resolve numerous matters. In the discipline of taxation, Eric was named a "Connecticut Super Lawyer." --- Send in a voice message: https://anchor.fm/rush-tech-support/message

Jeffrey Kess/MendenFreiman Jeffrey Kess is a partner in MendenFreiman s tax controversy and collection and tax planning practice areas. He joined the firm in 2019 and has practiced taxation and general business law for more than 35 years. He has achieved national recognition for his expertise in the field of tax controversy. Jeffrey has represented thousands […] The post Understanding the IRS Collection Process appeared first on Business RadioX ®.

Michael C. Whelan is a former IRS attorney, certified public accountant, and Chicago tax attorney who currently represents clients before the IRS Collection division as well as audited taxpayers.  Today we share his presentation, “Churn is a Choice” from MaxLawCon 2019. Watch the presentation here. Subscribe to our YouTube channel so you never miss an interview, presentation or training!

With IRS Enforcement increasing thanks to the new IRS Commissioner, and with more than 22 million taxpayers in need of help, this is the time to launch your Representation practice! Consider the following facts: There has been no better time to move your practice into the highly lucrative area of IRS representation. Check out Tax Rep LLC at TaxRepLLC.com and lets make 2020 the year you earn what you deserve! Looking for the Accountant's Guide to IRS Collection and Accountant's Guide to Resolving Tax Debts? Check them out here: TGPublish.com

With IRS Enforcement increasing thanks to the new IRS Commissioner, and with more than 22 million taxpayers in need of help, this is the time to launch your Representation practice! Consider the following facts: According to the IRS, there are 15 million taxpayers in the Collection Division inventory The IRS has announced it has identified more than 7 million non-filers it will be pursuing in 2020 The IRS is beginning enforcement sweeps in “underserved” areas of the US The average price of a 1040 tax return has fallen from $365 to $261 in the last 5 years Almost 60% of all Americans are filing their own tax returns (and screwing them up, creating more work for representation) There has been no better time to move your practice into the highly lucrative area of IRS representation. Check out Tax Rep LLC at TaxRepLLC.com and lets make 2020 the year you earn what you deserve! Looking for the Accountant’s Guide to IRS Collection and Accountant’s Guide to Resolving Tax Debts? Check them out here: TGPublish.com

There are lots of strategies to improve your clients' chance of settling their tax debt, but things can get sticky for those of us who practice in a community property state. The impact of “Community Property” laws can drastically change the outcome for your client. Joining Eric is Attorney Jason Freeman who will explain how community property laws work, and what strategy can be used to help your clients resolve their IRS issue in a community property state. Want to Contact Jason? Email him at Jason@freemanlaw-pllc.com or visit www.freemanlaw-pllc.com

There are lots of strategies to improve your clients' chance of settling their tax debt, but things can get sticky for those of us who practice in a community property state. The impact of “Community Property” laws can drastically change the outcome for your client. Joining Eric is Attorney Jason Freeman who will explain how community property laws work, and what strategy can be used to help your clients resolve their IRS issue in a community property state.   Want to Contact Jason? Email him at Jason@freemanlaw-pllc.com or visit www.freemanlaw-pllc.com

In this episode, Travis discusses the Form 433A- The IRS Collection Information Statement.

  Date:   June 1, 2019            Attendee and Guest:   Kelly Coughlin, CEO, EveryDay CPA -                                           David Ronquillo - PART 1 Greetings, this is Kelly Coughlin, CPA, and CEO of EveryDay CPA providing tax accounting and revenue solutions to individuals and businesses throughout the U.S. In today’s podcast I am going to interview a former grizzly bear.  Yep!  In a former life, for 30 years, he was a grizzly bear who took the shape of an IRS Officer, seizing assets and pursuing DOJ tax lien foreclosures.  If you have done business with this man, that is, if you poked this bear you probably were having a bad day.  He has proved positive to my mantra that the IRS can be either a black bear or a grizzly bear, but regardless, a bear.  And do you know how to tell the difference between the two?  If you climb a tree to escape the black bear climbs up the tree to eat you.  The grizzly bear simply rips the tree out by the roots and eats you.  Regardless, don’t poke the bear.  David Ronquillo, did I say that name correct David? David:   Yeah, Ronquillo. David Ronquillo began his career as a revenue officer in 1980 in Seattle.  He has held positions as Field Collection Group Manager and Senior Collection Policy Analyst.  Currently, he is helping tax professionals increase their knowledge and skills representing clients who are dealing with the IRS Collection operations.  David, I want to welcome you to the EveryDay CPA Podcast and want to first ask you, in your past work, did you prefer climbing the tree or ripping the tree out by the roots? David:     Well, Kelly, I have never had it described that way as that grizzly bear but it’s certainly a lot easier to just simply rip the tree out by its roots because you will bring down the taxpayer out of the tree to do what you need to do. Kelly:    Well done, alright.  So, you prefer the rip the tree out method? David:   Yes, it’s always more effective.  We try to be effective when we are with the IRS. Kelly:     So, is it fair to say, David, that you have done your fair share of ripping the tree out? David:     Very much so because the Austin district was one of the top districts in the country that did seizures and my group happened to do a lot of them.  So, that’s what we were focused on, it was the enforcement and the collections.  So, yeah, there is a lot of trees that I ripped out.     Kelly:    Great!  Alright, let me just ask a handful of questions here David and if you want to go a certain direction, feel free. But I am going to ask some questions that I think are kind of practical real-life issues that taxpayers that have poked the bear, I suppose, that they have to deal with.  Let’s talk about LLCs, for instance, does running your business revenues and expenses through a single-member LLC offer the taxpayer, that single member, any protection from IRS collection? David:    Not really, not to any great degree.  The IRS, they have various procedures for dealing with LLCs and I would always recommend to a tax practitioner, if his client is an LLC, to read the internal revenue manual procedures.  There are a number of pages to it as to how revenue officers should be dealing with the LLC. The single member, it depends on what type of tax that is owed.  Generally, what the IRS sees is that the LLC will have employees and they will run up employment tax.  Back in January of 2009 the IRS council came out with an opinion that effective after January 1, 2009, the trust fund recovery penalty would be used against the single member, against the individual to collect the trust fund portion of the employment tax.  Prior to that the IRS just said that the individual and the LLC were one and the same, whereby, the individual would have to pay the full amount of the employment tax, both the trust fund and the non-trust fund.   Kelly:  Well, that kind of applies to seed corps too, it Is that the executive team, maybe not shareholders but board members, for employment tax they look through to everybody for that, correct? David:    Exactly.  With the seed corporations, they look at the individuals that are responsible for making sure that the employment tax was paid and then who basically did nothing to see that it was paid. On the trust fund recovery penalty there is two standards the IRS has to meet.  One is responsibility and the second is called willfulness. So with the individual responsible for ensuring that the employment tax was paid, and if they weren’t then were they willful?  Did they know about the tax and what did they do or not do to ensure that the tax was paid?  And when you look at a business entity, corporation or an LLC, the IRS is to look to all the individuals that may have had a place in dealing with the employment tax.  So, it doesn’t necessarily have to be a corporate officer, it could be somebody that they just hired, the chief accountant, for example, who is responsible for making payments, paying the employment tax, making the FCDs. They could go after that individual.  I like to use an example in my teaching, it is that if you had two corporate officers, a president, and a vice president, it was a construction company, and one of them spent nearly 100 percent of their time in the field, you know, managing construction projects, even though they may be an officer, if they were not aware of the employment tax or they really had no control over the funds they would not be held liable for the trust fund recovery penalty.    Kelly:    Okay.  Well, the whole topic of employment tax is one of almost a subject of a separate podcast which we could focus on but if we continue on that, let’s say that you have outsourced.  With many small businesses, they outsource to, say, I’ll mention some names, QuickBooks, being the top one, and then Gusto, and a couple of these other ones that are in the payroll tax area, if you have outsourced it to them, how deep do you have to get in to first make processes to get assurance that, let’s just pick on QuickBooks for instance, Turbo Tax or Intuit, I should say, that they actually have made the distributions and payments of employment tax or once we outsource that, is it kind of not in the employer’s risk category at this point? David:     The Corporation or the individuals running the corporation, they cannot outsource the responsibility for making sure the employment tax is paid.  What the IRS would expect them to do is that if the FCD is due on a Wednesday that the officers, whoever is responsible for ensuring the employment tax to be paid, would check their bank statements or get some verification from, QuickBooks for example, that in fact the FCD was made.  And if it’s not made then the expectation is that individual would take some action to contact, QuickBooks, in this example, to find out, well, why didn’t they get paid, you know.  If the company had money in the bank account, well, why wasn’t it paid? So, they can’t outsource their responsibility. Kelly:    Alright, so they should go through one additional kind of review monitoring to make sure that (a) the funds came out of the account, which they most likely did. The question is, where did those funds go, and maybe check online to see if the FCD got paid and if there is any balance too; maybe not every time but maybe the first couple times, every disbursement, but then maybe quarterly. You develop some procedures around that activity.  Is that a fair statement? David:    Exactly right.  Have some procedures developed to verify that if somebody else is making your FCDs, that in fact they are being made.  Kelly:     Okay, so that’s enough on payroll.  But, my initial question was really not on employee tax, it was more about income tax, due.  Because your question was, well, it depends on the type, whether it be LLC, it does appear true.  So, we agree that there really is no protection for anybody on the payroll tax thing.  But on the income tax side, LLC versus not LLC, is there any protection in asset recovery, when you were in that business, if the business activity and the tax liability created was created by an LLC, single-member LLC, versus just a schedule C - sole proprietor?    David:    On an income tax situation where the individual owes this 1040 tax, well, the LLC is considered a separate entity from the individual so any assets owned by the LLC are protected from any type of enforcement action by the IRS. What the individual has is an interest in that LLC, that’s what he owns, so what the IRS would have to look at is, what is the individual’s personal assets?   So, for example, the residence, vehicles, bank accounts - personal, not LLC, but personal, okay? To get at the LLC, they would have to go after his member interest in that LLC, and that’s for income tax.  Kelly:     Right, so if there is no financial assets in that LLC, let’s say there is $10,000 tax due, there is no financial assets in there, there is only property, plant and equipment or let’s just say equipment, but the sole member has $100,000 in cash, can they seek recovery from that $100,000 in cash? David:     If the $100,000 in cash is in the LLC’s bank account… Kelly:      No, it’s in the individual. David:     Yeah, they can go after that.  Yeah, if it’s in their personal account, yes, the IRS can go after that, LLC regardless, they can go after that, the individual’s personal bank account. You’ve got a bank account, a Bank of America, where he writes checks to pay the mortgage and pay for groceries, yeah, the IRS can go after that. Kelly:    What about if it’s a dual member or more than one member LLC? David:    Then here that gets a little bit more tricky and, quite frankly, I would have to go back and read the rules on that.   Kelly:    Okay. David:   It’s almost, you know, they would be filing a 1065, a partnership, and with a partnership, the general partners are equally liable for the debt of the partnership.   But going the other way, the partnership is not liable for the debts of the individual if they owe 1040 tax.  I would have to go back and look at the IRM on that. Kelly:   Okay, but you are saying when you would seek recovery from assets it really didn’t make any difference whether that was an LLC or a single-member LLC or not.  You would order the owner of those assets, regardless, is that what you are saying? David:    Exactly, exactly.  There are ways that the IRS can, you know, if there are the indicators of not everything is being run above board, the IRS can go after the LLC or go after the individual, okay?.  

Date:   June 1, 2019            Attendee and Guest:   Kelly Coughlin, CEO, EveryDay CPA -                                           David Ronquillo - PART 2 Greetings, this is Kelly Coughlin, CPA, and CEO of EveryDay CPA providing tax accounting and revenue solutions to individuals and businesses throughout the U.S. In today’s podcast I am going to interview a former grizzly bear.  Yep!  In a former life, for 30 years, he was a grizzly bear who took the shape of an IRS Officer, seizing assets and pursuing DOJ tax lien foreclosures.  David Ronquillo began his career as a revenue officer in 1980 in Seattle.  He has held positions as Field Collection Group Manager and Senior Collection Policy Analyst.  Currently, he is helping tax professionals increase their knowledge and skills representing clients who are dealing with the IRS Collection operations.  David, I want to welcome you to the EveryDay CPA Podcast and want to first ask you: Kelly:    What about access to retirement assets, is that fairly standard operating procedure - Look for retirement assets - grab these, customer pays, taxpayer pays income tax and a penalty on that or are they exempt from the payment? David:   Levying retirement accounts is one of the last things the IRS wants to do.  They will do it in what they call egregious cases.  That’s where you have a taxpayer that’s just really isn’t cooperating, yet, the internal revenue manual gives some examples of how to identify egregious, you know, one of the other things is that they continue to make contributions to their retirement account.  The big thing about retirement accounts is whether the taxpayer has access to it or not.  So, for example, if the taxpayer can take the money out of the retirement account, IRS can levy, if they can borrow against it, IRS can levy.  But in some situations where the taxpayer cannot do anything with that retirement account, you know, the way the plan is set up they have no access, they basically have no interest in that retirement plan, the IRS cannot get it.  To get a retirement account, an IRA, for example, that has to go up to three levels of management for approval.  There has to be a good reason why the revenue officer wants to levy it.  Only revenue officers can levy retirement accounts.  The automated collections system, the telephone call sites cannot, it has to come up to a revenue officer.  So, they have to justify,  you know, write up a memo justifying why they want to levy the retirement account, they send that up the management chain, up to the area director who, if everybody agrees, they sign off on it and then the levy is served on the retirement plan.  So, it’s a lot of work that the revenue officer has to go through.  It’s a last end of the line procedure to do.  The revenue officer knows that his or her stuff is going to get reviewed and so they have to have a good justification as to why they want to do it.  So, it doesn’t happen very often but, yes, it can happen. And it comes down to the manner of cooperation that the taxpayer gives the revenue officer. But IRS changes its procedures last summer where now a taxpayer can ask the IRS to levy their retirement account. I have had two clients that have one of that done because what it does, it avoids that 10 percent early withdrawal penalty, but it’s convincing the revenue officer to do it.  In these particular cases, the individuals had like $200,000 in their retirement accounts that would fully pay the tax.  So, it’s the matter of going to the revenue officer, basically, make the case for them to do the levy, they run it up the line, levy, the tax gets paid. Kelly:    Why are they so hesitant to want to go after retirement assets, for the obvious reason,   don’t want to put retirement in jeopardy? David:    Yeah, exactly.  The national taxpayer advocate has made a big issue over it, IRS going after retirement accounts, because of it jeopardizing an individual’s retirement, and that’s basically it. So, in fact, she is somewhat opposed to the fact that a taxpayer can go in and ask the IRS for a levy. I have read in the last report, or maybe it’s the last two years report where they were hesitant to do that, but as I said, these two clients that I had, that’s what they wanted, that’s how they sort to rid of their tax liability.  And they had the ability to make a lot of money so they weren’t that concerned about them taking the money.   Kelly:    Okay. Would the IRS force taxpayers to sell their home to recover tax liability? David:    They may, it depends.  The first thing you have to look on, on a resident’s personal residence, how much equity is in there.  For IRS to seize an asset generally what they do is take 60 percent of the fair market value and then they will look at any encumbrance against it.  So, for example, with a home, let’s say, for example, it’s worth $100,000, they would start with 60 percent of that which would be $60,000, then the next question is, how much is the mortgage against it? And if the mortgage is more than 60 percent, in this case, more than $60,000, there is no equity for the IRS to seize.  But if it’s less, let’s say, for example, the mortgage was $20,000, you have got a $40,000 difference there between the $60,000 and the $20,000 then they would look at it.  What they would do is ask the taxpayer to go borrow against the equity, go refinance the house.  And sometimes the revenue officer may ask for the taxpayer to go to attempt to borrow from three different lending sources to get, if they are not approved, at least get the denial letters,  the loan denial letters, okay?  In those instances, if they are not approved for a loan the revenue officer may decide, well, you know, they are not approved, we are not going to take the house and we are just going to let it go, and put them on a payment agreement. In other cases, the revenue officer may decide, no, there is sufficient equity in there so we are going to go after the home. If they decide to pursue seizure of the residence, again, they have to go all the way up to the area director, three levels of management, to get approval, then the case goes over to the Department of Justice, Civil Tax Division, who then takes the case before a federal district court judge to get approval.  So, residential seizures have to be approved by a federal district court judge. Once they get the approval then they can go in and seize the residence and put it up for sale. Kelly:   Is it easier for the IRS to get retirement assets or to get personal residence, generally speaking? David:    Oh, retirement assets.  Kelly:     Are easier? David:    Very easier. They are easier to get. Kelly:     Okay. David:    So, you know, it comes down to how egregious the case is.  How much equity are they looking at? What kind of cooperation are they getting from the taxpayer?   Kelly:    Hey, when you say egregious, are you talking about the liability, size of the liability, or the reason for the liability, you know, civil fraud, that sort of thing? David:    It’s the reason for the liability and the level of cooperation that they are getting from the taxpayer.  You know, we have had taxpayers that they don’t cooperate at all.  They don’t contact, they wouldn’t contact us.  You get in touch with them, they are argumentative, you know, they are not going to do what you ask them to do.  And you could be in a situation where really the only thing you can get is their personal residence, and there is sufficient equity in there that’s going to make a significant dent in how much they owe.  And you look at the background and say, well, how did they run up the tax, you know?  It could be a trust fund recovery penalty where they had a company that they ran up, you know, a million dollars’ worth of employment tax.  So, all of the taxes the IRS has to take into consideration. Kelly:     Okay.   How much of the individual IRS representative personality influences the outcome and direction of a case, or, another way of putting it, if you are not getting along well with this particular agent, can you get a different one assigned to it? David:     The simple answer is no. There would have to be some facts and circumstances on how the interaction is going between the taxpayer and, let’s say, the revenue officer for IRS management to move the case.  Simply disagreeing with the decision that the revenue officer made is not going to move it.  The revenue officer would have to be doing something whether violating policies or procedures or they may be harassing the taxpayer or just really totally out of bounds with the taxpayer.  The taxpayer can go to the group manager and ideally they would have documentation to that effect, you know, maybe quotes of what the revenue officer said to them, maybe what they proposed to the revenue officer to resolve the case, and why the revenue officer is rejecting it.  That type of instance, you know, the manager would consider, maybe we should move the case, but generally, it’s very very, very difficult.  Kelly:     Give us some background on how and where cases are assigned. David:     IRS has different stages.  When a tax return is filed and there is tax due on the case it goes through what’s called the notice stream where, issues, on income tax, for example, four notices will be sent out to taxpayer. Kelly:       What notices, form?  F-O-R-M? David:      No, four, F-O-U-R. Kelly:       Okay.  David:      Four notices, and generally, the notices get a little bit stronger as they go down the line.  They generally come out four to six weeks apart, but I have seen instances where a taxpayer would get a second notice and they never get a third notice and never get a fourth notice. The third notice is called a CP504.  If you look in the upper right-hand corner of the letter it will say CP504, saying intent to levy. And the paragraph will state that the IRS can levy basically on state income tax refund. So, in states that don’t have income tax, really the notice is meaningless, nothing can be done.   So, for example, here in Texas we don’t have state income tax when our client gets that notice we just know, well, we are probably going to get the final notice here, another four to six weeks from now, but basically, we can ignore that notice.  In California, for example, with the state income tax, the IRS can levy the state refund if the taxpayer is due one.  The final method can be what they called LP11, and that comes out of ACS or it can be LP1058 which comes from the revenue officer, it will stay on it in big bold letters, final notice of intent to levy.  The taxpayer has appeal rights with that.  They can file what’s called the collection due process request within 30 days of that notice which will stop all enforcement.  The IRS cannot levy unless it’s a jeopardy situation, and those are rare.   And what happens with filing the notice is, you request a hearing with the appeals division and in the meantime you can get your financial statement together, a case resolution proposed, and you are supposed to be able to work still with the revenue officer but what we have seen is a lot of revenue officers just take that and send that up to appeals.  If there is no response then we are talking about going back to the notice stream where an auditor does not have the case, if the case is large enough in dollar-wise, and generally it’s $100,000 or more, it may be assigned out to the field to a field collection group, to the revenue officers group, okay?  IRS has algorithms where they score cases, and they look at, they classify cases, high risk or medium risk or low risk, and they look at the probability of collecting what is owed. Their algorithms can figure this out. The case is scored, it is sent out to a revenue officer group.  When it gets into a revenue officer group, it goes into what’s called a queue, like a holding file.  So, as revenue officers need cases because their inventory is limited to a certain number of cases that didn’t work, as they need cases the group manager would pull the case out of the queue and assign it to the revenue officer to work.  That’s basically how the cases are assigned from the very beginning where the return is filed all the way where it gets out to the revenue officer.   The permutations in-between, you know, different things can happen, but generally, that’s the way it works.   Kelly:   So, you said they are scored, give me some ideas on the algorithm, if you will, some of the calculus that goes into that? Does it get a high score if there are assets to be recovered and it’s more likely to recover those things   and then those get elevated and accelerated and get the attention and then if it gets  a low score, does it go down the path of, currently not collectible, that kind of thing, is that how that works? David:    Yeah.   But say for example we have an individual that earns $200,000 a year in W-2 income or even 1099 income, the IRS knows about that.  Say, for example, they have mortgage interest on their tax returns, the IRS knows about that.  So, based on what’s on the tax return and other data that the IRS will pull they will look at that type of data and generate a score.  Probably, in this case, a high score because there is a source of income and they have assets.  So, conversely, if you have an individual that, let’s say they make, I don’t know, $30,000 a year, and that’s all they got, they file a 1040EZ, they may owe tax, they may have accumulated tax over a number of years, but if you are choosing between who you are going to go after to collect, you go after the individual that’s making $200,000 a year versus the one making $30,000.  There are instances where they can never get to the person that is making $30,000 a year and they may owe, let’s say they owe $100,000 that has accumulated over a number of years, that case will just simply sit in the general IRS, queue and the statue will continue to run and when the 10 year statute is over the tax is wiped out.  So, there is millions of dollars that are written off every year because the IRS simply can’t get to the case, it’s not scored high enough and they don’t have the resources to get to it. Kelly:    Yeah.  Now, in that $30,000 income situation, the IRS would most likely file a lien just in case there were some assets that appeared that they could then sort of collect from that.  Is that a fair statement? David:     Yeah, generally, I think it is a pretty safe statement. Filing the tax lien is automatically generated by the computer system.  The threshold for filing a tax lien is like $10,000, even you have instances, and I have seen them, where the tax lien is filed but then nothing else happens, there is no further collection action.  There is no levies, there is no other notices but the tax lien sits there.   But, notice that several tax liens collect millions and millions of dollars every year without the IRS doing anything, just file the tax lien and then, you know, a few years later after it’s filed, the taxpayer goes and sells a piece of real estate and, boom, that tax lien is there and the sale isn’t going to go through once that tax lien is dealt with. Kelly:     Dude, Is there a statute of limitation on that lien? David:     No, it’s 10 years, ten years to the date of assessment.          Kelly:      Yeah, right.   Because it appears, as you have seen on TV, a lot of these companies are out there Optima Tax and there are others out there that are really aggressively pursuing this tax resolution business.  I assume that they are targeting these tax liens that are on file.  That’s about the only public record of a federal tax lien, correct? David:      Yes, from what I understand, there are other companies out there that would generate lists you can get of people that have tax lien filed against them that they can break it down by counties, cities, state, you know, and they can break it down by dollar amounts and then these companies buy these lists and then do their marketing to them, you know, direct mailing, postcards, letters, things like that.  How effective that is? I don’t know if it’s that effective or not. We have had clients come in and say, yeah, I got all these letters from all these different tax resolution companies, how did they get my name?  And I said, well, the tax lien filed against you, that’s how they get it.                                                                                                                           

Greetings, this is Kelly Coughlin, CPA, and CEO of EveryDay CPA providing tax accounting and revenue solutions to individuals and businesses throughout the U.S. In today’s podcast, I am going to interview a former grizzly bear. Yep! In a former life, for 30 years, he was a grizzly bear who took the shape of an IRS Officer, seizing assets and pursuing DOJ tax lien foreclosures. David Ronquillo began his career as a revenue officer in 1980 in Seattle. He has held positions as Field Collection Group Manager and Senior Collection Policy Analyst. Currently, he is helping tax professionals increase their knowledge and skills representing clients who are dealing with the IRS Collection operations. David, I want to welcome you to the EveryDay CPA Podcast. Kelly: I have a couple more questions on kind of the behind the scenes dynamics of the collection area, one is, what are some of the motivators or behind the scenes incentives that influence an agent that works on these cases, that work in favor of the taxpayer, and certainly which ones don’t work in favor of the taxpayer? I am thinking, you know, there is a pressure to close the case to get it off the table, right? We have heard all that, is that a fair statement, that there is the pressure to gets things closed, right? David: Right. Kelly: Does that pressure help the taxpayer or hurt the taxpayer or is a neutral? David: It can depend, and I can see it go both ways, for example, if it’s an egregious case, you know, the way that they ran the tax up, you know, a trust fund recovery penalty is a classic example. IRS may spend more time on it digging for assets or digging for a way to collect what is owed, simply because of the way the tax was generated or how cooperative - did they do what the revenue officer asks them to do or are they going out to try to refinance their house? So, in those instances, the case may be directly classified as a case that’s over-age. It used to be nine months. If the case was older than nine months in the inventory it was over age so then management starts looking at it a lot closer trying to figure out, what do we need to do to close this case? But if it’s a good enough case where it should not be closed, the IRS is not going to close it. On the other hand, if it’s a simple payment agreement, taxpayers can come in, they can make monthly payments, case is getting old, hey, let’s get the payment agreement written up and let’s get it closed. Let’s move on to something else. So, the pressure on closing the case can work both ways, it just depends on what your circumstances are. In dealing with the revenue officer, I always take the choice, because I hear these advertisements on the radio, oh, yeah, we do battle with the IRS, we fight the IRS, this and that. I don’t fight the IRS because it’s not effective. When people would fight me or fight my revenue officers, it was never effective because I used to tell taxpayers when I was a revenue officer, you don’t want to cooperate, fine, I will clear my desk and I will just have your case on my desk and I will spend all my time on it trying to figure out how I am going to collect from you, okay? So, because you are having an interaction with another individual, another human being, and people like to be treated well, like to be treated nice, the revenue officer is the same way, they go home from work to a family, to a family dog, they are regular people. So, I always advocate, try to solve the case for the revenue officer. If you know what the rules are, the procedures are, what the internal revenue manual calls for with the case within those parameters. If they owe tax you know that the revenue officer is going to want a 433-A, a financial statement or if it’s a business 433-B, you know what the standards are, don’t ask the revenue officer to grant $5,000 expense for mortgage and utilities when the standard for the area is like 2,000 bucks. So, work to resolve the case for the revenue officer, that way they don’t have to spend as much time of concentration on your case. Be cooperative, you have got a deadline, try to meet the deadline. If you can’t meet the deadline, at least call the revenue officer ahead of time and say I can’t meet the deadline and this is why, and generally they will extend the deadline. Don’t argue with them over issues that are not important, okay? In my example, the mortgage and utilities are $5,000, the standard is $2,000, why are you arguing with them over that? You probably won’t get it. I mean, you can put a little bit, but why, “Here is all the utility bills and this is why.” But I would much rather spend my time arguing with the revenue officer over something that they did wrong rather than something that I know my chances of winning are slim to none. Kelly: You keep referring to the revenue officer, what’s the hierarchy of IRS case management, the point of contact, taxpayer? And, parenthetically, I am going to assume that you recommend in most cases that a taxpayer get help from a professional that knows how to navigate these areas, is that a fair statement? David: Yeah, It is. It depends on the case. It depends on how much the taxpayer owes. If the taxpayer owes $5,000 and they can pay $500 a month then I would just tell them, hey, call the IRS or send in a letter to the IRS that you want to make a monthly payment agreement. If they owe $50,000 or $150,000 then that’s a lot different, and then it depends on what they have. Taxpayers, what I have seen, they don’t want to spend their time trying to deal with the IRS. They don’t know how the IRS works; they don’t know how the IRS thinks; they don’t know the IRS language and they don’t know what the IRS can do to them. And I have had taxpayers come to me after they have dealt with the IRS, and generally, they have a deadline put on them and now they want me to fix the problem. And that’s like, well, you’ve got a deadline from the IRS which is in three days and you expect me to do all this work for you, and if the work is not done, financial statement is not submitted, they are going to lobby. I can’t guarantee you that I can do this. My recommendation to taxpayers is, do not contact the IRS. Generally, if you owe enough money and you don’t feel confident in dealing with the IRS, contact a professional that knows what they are doing, knows how to deal with the IRS, because you’ll probably sleep a lot better at nights rather than you trying to deal with the IRS. Kelly: And if you are a tax professional and you don’t know how to navigate through this side of the IRS area, the collection area, then that’s your focus now in your business enterprise, correct? You are helping tax professionals navigate through these waters? David: Yes. I am going to stop representing taxpayers, simply, because I have done it for close to 40 years. And what I would rather do now is just simply act as a consultant to tax professionals. If they have questions, I’ll help them develop strategies on particular cases. You know, I attended the National Association Enrolled Agents conference at Las Vegas every year and those are good conferences but what I see happening is that you have folks coming in and they kind of learn representation to add it on to their practice, which is good, but you sit there in a seminar for an hour to an hour and a half to two hours, for example, on filling out a financial statement, 433-A, that’s really, in my opinion, not enough, because there are implications to what you put down on that 433-A. Anybody can fill it out because you are just putting down numbers. So, if you write down for real estate, three bedrooms, two bath resident, that its fair market value is $500,000, and the mortgage against it is $100,000, for equity of $400,000, you have to know how the IRS is going to look at that $400,000, especially a revenue officer. You just can’t submit that 433-A and say to a revenue officer, here it is, and have yourself wide open or no prepare your client. The revenue officer is going to ask you to go borrow, so let’s get started right now. Kelly: Right, right. David: So, the seminars are good but until you really get out and start working cases, Offers in Compromises is another one, the Acceptance Rates on Offers in Compromise is just under 50 percent. I don’t submit a lot of offers but everyone, I’ve probably submitted maybe about 10, 15, at the most, everyone has been accepted except for one, and that is because she went and got a job, that increased her income which kind of blew the offer up. You know, you have to be really, really careful on what you are doing so that you can achieve success for your clients. So, my plans now going into the future is, do consulting work. People want to call me up, this is what I have got, this is the type of case, I can kind of walk them through it, and try this, this and this, and if that doesn’t work, you know what, let’s try this. And just, you know, basically be a coach is what I want to do. Kelly: Yeah, got it. So, back to that question, hierarchy of case management, you have got the revenue officer, the next level up from that, like his supervisor, what do you call that supervisor? David: That is the group manager, and that group manager is going to supervise anywhere from 10 to 15 revenue officers; above that is the territory manager - that was my last position, it was a territory manager, and they are supervising anywhere, nowadays, because the personnel has shrunken, you know, five to 10 groups. And then above the territory manager is the area director and he or she is supervising…They have States, like here in Texas we are a part of the golf state area, that area director is in Huston. And golf state, they did some reconfiguration, but it used to be Texas, Louisiana, Alabama, Mississippi, Georgia and Tennessee, and, I think, Arkansas. Kelly: Okay. So, back to revenue officer, so, let’s say we have got a revenue officer that says, I want to go after retirement assets, I think earlier you said they have to go up three levels so does that mean it goes to the area director or the territory manager? David: Goes to the group manager, the group manager forwards it to the territory manager who forwards it up to the area director. Kelly: Alright. David: Every area has what’s called a technical analyst and this person will review the case for the area director, looking at the technical aspects of the case - does it meets the requirement for whatever the revenue officer is asking for? And if the technical analyst says, yes, this is good, they will give it to the area director and then he or she will sign off on it and they’ll go and come back tomorrow and open the levy. Kelly: That’s retirement assets and then the personal residence, same thing but it goes up one level above that, did you say? David: Yeah, it will go up through the area director and then it goes over to a special unit called advisory, and these are senior revenue officers that will look at the case again for technical issues. Does it meets the technical, the legal and technical, does it meets the requirements for doing the seizure? The case will then move over to IRS council’s office for review. They will review it for the same thing and they will then forward it over to the Department of Justice Civil Tax Division for the DOJ to take it in to Federal District Court to get an appointment to take it to the Federal District Court. Kelly: Okay, that’s very helpful. I have two final questions, unrelated, where you talked about OIC and some of these other tactics that are used to deal with liabilities. Let’s talk about CNC, Currently Not Collectable, once a tax liability goes into CNC classification that kind of puts everything on hold, there is no more collection activity, when does it get further attention, it won’t stay in there forever? What’s the catalyst to get it out of that, is it a tax return that gets filed and then the IRS notices, oh, this guy is making ten times the income now, is that more or less what happens? David: That is what happens, the IRS when they see a case they will set an income threshold. It’s in the internal revenue manual on how they calculate that. What they are looking at is necessary living expenses, and they set the threshold a little bit higher than what the necessary living expenses are because they don’t want a case that is generating out just because the taxpayer went $5 over what their necessary living expenses were, but they’ll set a threshold and then when subsequently file tax return, the income will be matched up against what the threshold is. And if their income is now greater than what the threshold is the case will then be regenerated out for collection because the assumption is the taxpayer is making more money now they can start paying towards something. If the taxpayer never exceeds that threshold the case will never come out, the statute will expire and that will be the end of it. Kelly: Alright, okay. David: And even, I think, if the taxpayer doesn’t file tax returns it won’t be put out of CNC status but what will happen is the IRS will be asking for the tax returns which is a whole other area to go into. Kelly: Yeah, right, right, okay. Alright, the final question is on internal collection versus external collection. A part of these ads we see on TV is, the IRS has hired a bevy of external collection agents that will really go after you, if you think your life was bad before, it really will be bad now. What are the facts on that? David: Now, there is big controversy over these private debt collections. The National Taxpayer Advocate is definitely opposed to it. IRS management, they tried this a number of years ago because they want to assign the low hanging fruit to cases that they cannot collect, the CNC cases to these private debt collectors. The most that they can do is make a phone call, try to locate the taxpayer and make a phone call but when it comes to actually resolving the case, say for example it’s a CNC case, private debt collector gets in touch with them and the taxpayer says, well, okay, I want to pay $100 a month, that case has to go back to IRS. IRS has to set up the payment agreement. They have no enforcement authority, basically, they are just trying to talk people into paying what they owe, track them down and pay what they owe. Internally, like we said at the beginning, the brown bear can chase them up the tree but the grizzly bear can just rip the tree out, that’s what IRS can do. Kelly: Yeah, right. Well, that is terrific. So, your market now is to help tax professionals help other taxpayers with tax liability issues. How would you like them to get in touch with you, telephone call, email? David: My email is david@dfwtaxhelp. That’s delta foxtrot whiskey tax help, h e l p.com. I have a website dfwtaxhelp.com, phone number is 214.997.4470. Kelly: That’s great. David: Yes, people have questions, you know, and I will tell you, NAEA just came out with this forum where people can post questions, and I look at that sometimes and people will post a question on collection issues, maybe something on an offer, and various people will respond. And I look at that and I think to myself, the person that is asking the question is maybe getting two or three lines of an answer. And in a lot of stuff in collection there is permutations to it, there is different nuances that can occur. You can plan to go down one path and you have to know what’s down that path that can mess things up. So, I see that forum is good for quick short answers but if you really, really want to know how to handle a specific situation you really need to talk to somebody that is familiar with the situation that can give you some good directions, to give you good ideas on strategies of what to do. Kelly: That’s terrific. Well, David, I look forward to having you on my team to help me and my customers deal with this because I think you are a terrific resource to have and I am glad that that former grizzly bear is in my corner and are helping people. I like that. David: I like that. I will have to tell my colleagues that I am still with the IRS. It’s terrific. Well, thank you, Kelly. Kelly: Thanks. David: Alright. Kelly: I enjoy talking to you, great. Bye. David: Alright, bye, bye.

In this week's episode, Eric covers what is new in IRS collection and updates you on the latest changes to the Offer-in-Compromise program, passport revocation, and the latest collection and enforcement statistics just released by the IRS. Send your questions for Eric's AMA session (“Ask Me Anything”) and have your answers delivered on the podcast on June 14th while Eric is in Las Vegas speaking at the AICPA National Conference. Just email Eric at Podcast@TaxRepLLC.com

In this week’s episode, Eric covers what is new in IRS collection and updates you on the latest changes to the Offer-in-Compromise program, passport revocation, and the latest collection and enforcement statistics just released by the IRS.         Send your questions for Eric’s AMA session (“Ask Me Anything”) and have your answers delivered on the podcast on June 14th while Eric is in Las Vegas speaking at the AICPA National Conference. Just email Eric at Podcast@TaxRepLLC.com

Hey guys, the largest IRS Representation Conference in the country is now open for registration. The IRS Representation Conference will have close to 3,000 tax practitioners and cover everything you could want to know about what is hot in IRS Representation. Join me as I host the best conference with the top experts and government officials who will walk you through what you need to know right now to build your practice and protect your clients, as well as yourself! Just click on the link below and grab the early bird pricing and free Accountant's Guide to IRS Collection e-book (by yours truly). And remember – Tax Rep Members get FREE access, so if you've been on the fence about joining now is the time to do it! So whether you can actually come to Mohegan Sun or join us via live streaming webcast, you don't want to miss this super event! And if you do come please come up and introduce yourself. I love meeting all our network friends, and there is no better place to do it then at the beautiful Mohegan Sun Resort! Click here to register for the event! It's going to be awesome!

Hey guys, the largest IRS Representation Conference in the country is now open for registration. The IRS Representation Conference will have close to 3,000 tax practitioners and cover everything you could want to know about what is hot in IRS Representation. Join me as I host the best conference with the top experts and government officials who will walk you through what you need to know right now to build your practice and protect your clients, as well as yourself! Just click on the link below and grab the early bird pricing and free Accountant’s Guide to IRS Collection e-book (by yours truly). And remember – Tax Rep Members get FREE access, so if you’ve been on the fence about joining now is the time to do it! So whether you can actually come to Mohegan Sun or join us via live streaming webcast, you don’t want to miss this super event! And if you do come please come up and introduce yourself. I love meeting all our network friends, and there is no better place to do it then at the beautiful Mohegan Sun Resort! Click here to register for the event! It's going to be awesome!

This is an update on IRS Collection issues as they affect taxpayers in the following areas: financial standards in Collection Information Statements (CIS), the updated offer in compromise booklet, and the impact of the new law on the time to file wrongful levy claims. --- Support this podcast: https://anchor.fm/mike36/support

This is an update on IRS Collection issues as they affect taxpayers in the following areas: financial standards in Collection Information Statements (CIS), the updated offer in compromise booklet, and the impact of the new law on the time to file wrongful levy claims.

On this episode Dan Pilla joins Jim Paris to discuss the new tax cut, and how to solve a myriad of problems with the IRS - including what to do if you have not filed a tax return in several years, what if you get a collection notice from the IRS, how to protect your rights when the IRS is making a collection demand against you, and how to determine what taxes are owed on Bitcoin and cryptocurrency profits

In response to criticisms of the IRS's collection practices, and in an effort to create a more traditional debtor-creditor relationship between the TP and the IRS, Congress created the CDP procedures in 1998. Under these procedures, before the IRS can levy on the property of the taxpayer, it must give the TP the opportunity for review of the IRS's collection actions by the IRS Appeals Division. This presentation examines both steps of the CDP process: (1) administrative review at the Appeals level and judicial review of the Appeals determination. It focuses on how to request CDP consideration, how CDP hearings are conducted by Appeals, and what types of issues the Appeals Officer must consider as part of the hearing. Court review in CDP cases covers the following topics: (1) court jurisdiction over CDP appeals, (2) can a TP voluntarily dismiss a CDP case?, (3) the standard of review in CDP cases, and (4) is review limited to the records of the CDP hearing at the administrative level.

Are you wondering what will happen now that you can't pay your tax bill? If so, Darrin T. Mish. tax attorney, will break it all down for you in this episode of the IRS Solution Attorney.

If you don't pay your tax in full when you file your tax return, you'll receive a bill for the amount you owe. But do you know what happens after that? Tune into this vodcast of the IRS Solution Attorney to find out! https://getirshelp.com/

Taxpayers who owe money to the IRS should try to actively resolve their debt.  The IRS has many options from Offers in Compromise to Installment Agreements designed in order provide taxpayers with a fresh start.  If you currently have extensive tax debt and feel that you would benefit from the relief offered by the IRS, tune in to this podcast with Timothy Hughes of Lavelle Law to learn more about the options available to reduce or eliminate your tax debt. 

One of the most important rights available to taxpayers with past-due tax liabilities is the right to request a hearing within the IRS (called a collection due process, or CDP, hearing) to prevent collection action and to propose alternative methods of resolution. To protect their interests, it is important that taxpayers understand how and when to request these hearings. They also must understand what rights they have to request CDP hearings, how the CDP hearing process works, and what their options are at the conclusion of a CDP hearing.