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IRS Collections IRS Collections Tax Relief Articles

Taxpayer Not Entitled to In-Person Tax Collection Hearing


Dealing with unpaid taxes and the IRS bureaucracy can be challenging. Sometimes the key is to get in front of the right person at the IRS. But the IRS often refuses in-person meetings. The Roberts v. Commissioner, T.C. Memo. 2019-117, case provides an example of this. It involves the taxpayers request for an in-person collection […]

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IRS Collections IRS Collections Offer in Compromise Tax Debt Tax Relief Articles

Setting Off a Non-Tax Debt Owed by the IRS


If you owe back taxes but the Federal government owes you for some other matter, can the IRS offset the unpaid taxes with the amount the government owes you? The answer is more complex than one would think. The court addresses this in Tartt v. Commissioner, T.C. Memo. 2019-112. Facts & Procedural History The taxpayer […]

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IRS Collections IRS Collections Tax Relief Articles

What is a Genuine Opportunity to Dispute a Tax Liability?


Taxpayers are able to dispute a tax liability before the IRS can take certain collection actions. But what if the IRS does not afford the taxpayer with a genuine opportunity to dispute the liability as required by law? The court addresses this in Dood v. Commissioner, T.C. Memo. 2019-107. Facts & Procedural History The taxpayer […]

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IRS Collections IRS Collections Tax Debt Tax Relief Articles

IRS Tax Debts from Retirement Account Distributions


Retirement account distributions typically trigger sizable tax liabilities. These liabilities often go unpaid, which results in unpaid tax debts and IRS collection enforcement actions. With careful planning, sometimes these taxes can be avoided. Tax on Retirement Account Distributions Most distributions from retirement accounts trigger income taxes. This includes distributions from IRAs and 401(k)s. The idea […]

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IRS Collections IRS Collections Tax Relief Articles

Can the IRS Take My 401(k) Plan Account?


Can the IRS take my 401(k) plan account for unpaid taxes? Does it have to wait until I take distributions from the 401(k) plan account? The IRS recently asked its tax attorneys this question in CCA 201927019. About 401(k) Plan Accounts The 401(k) plan account is the most popular method for saving for retirement. They […]

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IRS & State Audits Tax Relief Articles

Deducting Travel Expenses for Travel Away from Home


Contractors and business owners are able to deduct travel costs for travel away from home. This typically includes mileage and lodging costs. The amount of these expenses can be substantial. The IRS frequently audits and adjusts these expenses. Even with perfect records, the expenses may not be allowable depending on where the taxpayer’s “tax home” […]

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IRS Collections IRS Collections IRS Levies & Liens Tax Relief Articles

Getting the IRS to Pay Your Attorney’s Fees


The IRS is required to pay a taxpayers attorney’s fees for defending unsupportable positions. This can even include attorney’s fees when the matter is settled administratively before court. But the IRS is not required to pay attorney’s fees if the IRS’s position is substantially justified. The Bontranger v. Commissioner, T.C. Memo. 2019-45, helps clarify how […]

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IRS Collections IRS Levies & Liens Tax Relief Articles

Designating Proceeds from Sale of Property Subject to IRS Lien


If a taxpayer wants to sell property subject to an IRS lien and the IRS agrees to allow the sale, can the taxpayer designate what tax period the proceeds paid to the IRS from the sale are to be applied? The IRS attorneys address this in CCA 201916009. Facts in CCA 201916009 In CCA 201916009, […]

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IRS Collections IRS Levies & Liens Tax Relief Articles

The Limits of the IRS’s Levy


If the IRS issued a levy notice to a third party to attempt to collect a tax debt, the third party is generally obligated to pay over to the IRS any money owed to the taxpayer. But how long does this obligation continue? Does it apply to future payments that the third party becomes indebted […]

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Tax Penalties Tax Relief Articles

Using the CDP Hearing to Challenge Tax Penalties


There are times when it is important to pick the right method of approaching a problem with the IRS. The VICA Technologies v. Commissioner, T.C. Summary Opinion 2019-7, case provides an example of contesting penalties in an IRS collection due process hearing. Facts & Procedural History The taxpayer was assessed a Sec. 6698(a) penalty for […]