In 2011 the IRS issued a new offer in compromise form. Taxpayers proposing compromises based upon doubt as to collectibility of effective tax administration must submit revised Form 656. Taxpayers proposing an offer based upon doubt as to liability must now submit Form 656-L and a narrative setting forth defenses to the liability. To comply with the new downpayment requirements taxpayers must submit Form 656-PPV with the required downpayment.
In this article, tax attorney Robert E. McKenzie discusses statutes of limitations.
Over the past several years as taxpayers have endured the Great Recession the IRS has escalated the number of federal tax liens filed against delinquent taxpayers. The IRS aggressive use of liens has been criticized by the National Taxpayer Advocate in her annual report to congress and the IRS Advisory Council in its annual report to the Commissioner. IRS recently announced a new, more flexible attitude in policies and programs to help taxpayers pay back taxes and avoid tax liens.
The IRS has several programs in place, including the Offshore Voluntary Disclosure Program. Even those…