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Offer in Compromise Tax Debt

IRS Ignore Your Offer in Compromise? What’s Next?


The IRS offer in compromise program provides taxpayers with a remedy for settling back taxes.  It can provide taxpayers with a much-needed fresh start.  Congress has changed the rules for offers.  One change is that offers are deemed accepted if the IRS does not reject them within two years.  This raises the question as to […]

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Bankruptcy Tax IRS Collections Tax Debt

IRS Can Avoid Bankruptcy Collection Hold


One of the benefits of filing bankruptcy is that creditors are precluded from taking collection actions.  When a taxpayer who owes unpaid taxes to the IRS files bankruptcy, this collection hold applies to the IRS.  But what if the IRS could simply file a motion and avoid the collection hold?  This is exactly what happened […]

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Currently Not Collectible Installment Agreement Offer in Compromise Tax Debt

Settling Unpaid Taxes With Sporadic or Seasonal Income


Sporadic or seasonal income can make it difficult to settle back taxes with the IRS.  For example, if you have a large one time payment that is not likely to continue, can the IRS consider this in evaluating how much you can pay the IRS?  The court addresses this in Margolis-Sellers v. Commissioner, T.C. Memo. […]

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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 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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Bankruptcy Tax Tax Debt Tax Relief Articles

IRS Pursuit of Additional Taxes After Bankruptcy


One of the benefits of bankruptcy is that it provides some certainty as to what is owed. If successful, the bankruptcy process can provide debtors with a fresh start. But things get complicated when taxes are involved. The recent Breland v. Commissioner, 152 T.C. 9 (2019), case provides an example whereby the IRS was allowed […]

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Installment Agreement Tax Relief Articles

IRS Installment Agreement Calculation Counts Spendthrift Trust Distributions


The IRS generally cannot reach funds in a spendthrift trust to satisfy the trust beneficiary’s unpaid tax debts.  But can the IRS factor in trust distributions in calculating the how much the taxpayer can pay under an installment agreement?  The recent Melasky v. Commissioner, 151 TC 9 (2018), suggests that the IRS can do this […]

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Bankruptcy Tax Tax Relief Articles

Discharging Unpaid Taxes in Bankruptcy


There are circumstances when unpaid taxes can be discharged in bankruptcy.  There are a number of rules involved.  They all hinge on whether a tax return was filed.  The recent United States v. Mayer, No. 16-626-RGA (D. Del. 2018), case provides an opportunity to consider these bankruptcy-tax rules. Facts & Procedural History The case involved the taxpayer’s […]

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Bankruptcy Tax Tax Relief Articles

IRS Cannot Collect Taxes Discharged in Bankruptcy


In Internal Revenue Service v. Murphy, No. 17-1601 (1st Cir. 2018), the taxpayer discharged his unpaid taxes in bankruptcy.  The IRS continued to try to collect the discharged tax debt.  The case is a must read for taxpayers who find themselves in this same situation. The Facts & Procedural History The taxpayer in Murphy filed Chapter […]

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Offer in Compromise Tax Relief Articles

Managing IRS Debts With Retirement Account Assets


Retirement accounts can present a number of challenges when trying to resolve an IRS debt. The IRS considers a retirement account as an asset in its collection analysis. The recent Scanlon v. Commissioner, T.C. Memo. 2018-51, court case provides an opportunity to consider the impact of retirement assets on IRS collection matters. The Facts & […]