FRESH START INITIATIVE 2012- Fresh Start Initiative For offers in Compromise 1.10 On May 21, 2012 the Internal Revenue Service announced another expansion of its "Fresh Start" initiative by offering more flexible terms to its Offer in Compromise (OIC) program…
This article by Robert E. McKenzie was was originally published in Forbes.
By Robert E. McKenzie Depriving Taxpayers of Administrative Due Process of Law Many 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…
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…
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.
8-24-12 Robert E. McKenzie Appearance on Money For Lunch Talk Radio
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 obligations.
“I’ve represented clients who paid large sums of money to each of those companies and were disgruntled with the services they received,” said Robert McKenzie, a partner in the Chicago-based law firm Arnstein & Lehr.
“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.
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 people.