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 of how…

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…

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…

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 &…