The federal tax lien is at the heart of all enforced collection action taken by the IRS Collection Division. Accordingly, representing clients requires an understanding of how the lien arises, the kinds of property to which it attaches, the consequences of such attachment, the duration of the lien, the priority of the tax lien over […]

This is the second part of a two-part article about the federal tax lien. The last article covered the nature of the lien, focusing primarily on its broad reach, attaching as it does to “all property and rights to property” of the taxpayer wherever situated. In the paragraphs below, we will consider the priority of […]

For those beleaguered souls for whom nothing else works, the only hope of relief from unmanageable federal tax debts may be the statute of limitations on collection. In theory, the IRS has only 10 years from the date of assessment to collect. However, this 10-year limitation is shot through with so many exceptions, waivers and […]

Never do today what you can put off until tomorrow . . . All of us procrastinate. But some take things to dangerous extremes — putting off the filing of tax returns for a few years, or even many years. The IRS estimates that each year some ten million people fail to file their tax […]

The road to Hell, so we’re told, is paved with good intentions. And on the road to Hell, failure to pay employment taxes is definitely the fast lane. The resulting “trust fund recovery penalty” can spell disaster for the hard-pressed entrepreneur, corporate manager, director, officer, or employee who falls victim to it. This article will […]

As all of us who represent taxpayers before the IRS Collection Division know only too well, the Revenue Officer handling a particular client’s case may not agree with our ever so reasonable suggestions about what should be done. In these situations, thanks to the IRS Restructuring and Reform Act of 1998, we now have greatly […]

Nothing in life is certain but death and taxes, and never more so than now. The reason is that two recent Supreme Court decisions expand the reach of the federal tax collector, and some assets which were previously safe are now in jeopardy. This article will discuss several situations in which the IRS now enjoys […]

Many people with tax collection problems feel like they’re in a combat zone, besieged by battalions of battle-hardened IRS Revenue Officers. But many tax practitioners, particularly those of us here in the Washington metropolitan area, will encounter clients who are or have recently been in real combat zones — places like Iraq, the Persian Gulf, […]

Knowing how the IRS Collection Division treats pension benefits and retirement savings is an important part of understanding a client’s situation and helping the client plan a course of action to resolve his or her unpaid tax liabilities. Pension benefits and retirement savings often constitute a client’s most valuable assets, and are viewed as a […]

The IRS today announced a very brief extension of the current initiative aimed at facilitating the disclosure of previously hidden offshore accounts. The settlement program was due to expire on September 23rd, but it has now been extended to October 15th, giving taxpayers another three weeks to come forward with information about their previously undisclosed […]