When a taxpayer requests an installment agreement for larger tax liabilities or proposes an offer in compromise, the IRS applies allowable expense standards. Total allowable expenses include those expenses that meet the necessary expense test. The necessary expense test is defined as expenses that are necessary to provide for a taxpayer’s and his or her family’s health and welfare and/or production of income. The expenses must be reasonable. The total necessary expenses establish the minimum a taxpayer and family needs to live and serve as the basis for granting installment agreements and offers in compromise.
“Chicago tax lawyer Robert E. McKenzie worries those with still secret offshore accounts may be less likely to disclose because they figure that if they’re found out and prosecuted, they’ll avoid jail as Warner has. But McKenzie tells prospective clients the same thing he wrote recently on Forbes: ‘Many other less lucky offshore depositors have been sentenced to prison by other judges. One distinguishing factor for Warner was that he was a billionaire whereas those sent to prison were merely millionaires.'”