Is Homeless a Requirement for an IRS Payment Agreement?

Indifference. It is generally defined as “lack of interest, concern, or sympathy.” Those who are unfortunate enough to work with the government employees to resolve a case or matter often have a profound understanding of this term. This is true of just about every government function–be it local, state, or federal. When it comes to…

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. 2019-165…

IRS Payment Agreement & 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 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 but…