The last article in this series on dealing with the Collection Division addressed Installment Agreements — arrangements through which tax debts can be resolved by means of monthly payments. Some folks, however, owe so much that an installment agreement is not a practical solution. Interest and penalties can accrue so quickly that the liability actually […]

Scarlett: But Rhett darling, our Separation Agreement requires you to pay any taxes resulting from the IRS audit that was going on during our divorce. Now Revenue Officer Sherman has levied my wages and seized my horse and my last mint julep! Rhett: Frankly, my dear, I don’t give a damn. Sound familiar? Ever represent […]

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, […]