Audits

IRS Revenue Officers continue to become more aggressive in the field. Here is a new approach to look for: I had a recent case in which a Revenue Officer sent my client a notice stating that that there would be an interview at my client’s house.  These meetings usually take place at an IRS office. [...]

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Tax Court judges have experience either as former government lawyers or in the private sector at law firms. Of the thirty-two Tax Court judges, thirteen previously worked for the government as IRS lawyers; four were employed by the Department of Justice’s Tax Division.   The remaining judges have legal experience in the private sector (with [...]

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I received this referral this week about eliminating taxes in bankruptcy: I was audited for my 2005 taxes and owe $55,000 to the IRS as a result.  I owe other debt in addition to the IRS liability, and was considering bankruptcy even before an IRS Revenue Officer came to my house and left her card [...]

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I hear this often when I suggest bankruptcy as a source of resolution.  I heard it again today during a telephone conversation with a new client.  Here is what I explained to the client: Under the bankruptcy code, the answer is ”Yes” to bankruptcy as a means of IRS resolution if you owe income taxes, you filed your returns, and [...]

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This is frustrating, and has happened to my clients in the past. The IRS does not want the compromise to default any more than you do. The IRS wants to give you an opportunity to remedy a potential default in an already accepted compromise. There are three primary ways the IRS will consider defaulting an [...]

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I just settled an audit on behalf of a client that had to make its way to Tax Court to be resolved.  The audit was caused by significant losses my client claimed on rental real estate.  But it but morphed into an IRS investigation of her banking statements and deposits.  Taking a case to Tax [...]

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