Offer In Compromises Made Easier

Offer In Compromises Made Easier


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Nominee Liens And Alter Ego Liens

Nominee Liens & Alter Ego Liens

By Robert E. McKenzie ©2012



Depriving Taxpayers of Administrative
Due Process of Law

practitioners have observed the aggressive approach that the IRS has recently
taken to collect taxes from alleged nominees and alter egos of delinquent
taxpayers. This summary collection approach deprives the alleged nominees of
administrative due process of law. In most [...]

IRS Collection Standards for Living Expenses

Below are links to the latest revisions of the national standards used in collection financial analysis. The charts show the itemized monthly national standards and the total money national standards as revised in March 2010. The new standards are effective for financial analysis conducted after publication.

Allowable Expenses for Food, Clothing and Other Personal Expenses

Out of [...]

Reducing IRS Penalties

Procedural Requirements for Imposition of Penalties and Additions to Tax
The Internal Revenue Service Restructuring Act required that each notice imposing a penalty include the name of the penalty, the Code section imposing the penalty, and a computation of the penalty. The Act also requires the specific approval of IRS management to assess all non computer generated penalties unless excepted. This provision does not apply to failure to file penalties, failure to pay penalties, or to penalties for failure to pay estimated tax. [...]

5-27-12 Forbes Blog: New IRS Offer In Compromise Policies

Over the years the IRS offer in compromise program has been the subject of a great deal of criticism by Congress, the National Taxpayer Advocate and taxpayer representatives. The new initiative represents the most dramatic liberalization of IRS settlement policies ever announced. It represents a welcome change from an agency which has always placed substantial roadblocks to those seeking to compromise their tax [...]

Robert E. McKenzie Quoted in Accounting Today on the Bankruptcy of Widely Adverised Tax Resolution Firms

“There are still lots of tax resolution services out there, but the three that filed for bankruptcy—TaxMasters, Roni Deutch and JK Harris—were the ones that engaged in heavy duty advertising on a national scale,” said Bob McKenzie, a tax partner at Arnstein & Lehr. [...]

Forbe Blog: IRS Offers New Penalty Relief to Taxpayers

On March 7, 2012 the Internal Revenue Service announced a major expansion of its “Fresh Start” initiative to help struggling taxpayers by taking steps to provide new penalty relief to the unemployed and making Installment Agreements available to more [...]

1-28-12 Forbes: Revised IRS Installment Agreement Rules

1-28-12 Forbes: Revised IRS Installment Agreement Rules


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IRS Revised Rules for Streamlined Installment Agreements

Robert E. McKenzie ©2012

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The IRS recently relaxed its rules for payment of smaller tax liabilities. The revised procedures now allow taxpayers up to 72 months to pay their tax obligations. The new procedures also increase the maximum amount subject to the relaxed streamlined agreements from $25,000 to $50,000.

You may request a monthly installment plan [...]

Tax Obligations Before and During Bankruptcy

For bankruptcy cases filed after October 16, 2005, the Bankruptcy Code requires Chapter 13 debtors to file all required tax returns for tax periods ending within 4 years of the debtor’s bankruptcy filing. All such federal tax returns must be filed with the IRS before the date first set for the first meeting of creditors. The debtor may request the trustee to hold the meeting open for an additional 120 days to enable the debtor to file the returns (or until the day the returns are due under an automatic IRS extension, if later). After notice and hearing, the bankruptcy court may extend the period for another 30 days. Failure to timely file the returns can prevent confirmation of a Chapter 13 plan and result in either dismissal of the Chapter 13 case or conversion of the case to a Chapter 7 case. [...]