Thomas B. and Labelle B. Lance v Commissioner of Internal Revenue- In this case the taxpayers requested an offer in compromise on the basis of doubt as to collectibility or, in the alternative, an installment payment arrangement, but refused to provide to the IRS officer a completed collection information statement. The IRS officer did not give the [...]
Entries Tagged as 'Offers in Compromise'
Tax Court Update – June 4, 2009 – Failure to Provide Finanical Statements
June 8th, 2009 · 2 Comments
Tags: Court Cases · IRS Installment Agreements · Offers in Compromise
Is IRS Offer in Compromise Program a Sham?
March 10th, 2009 · 10 Comments
The National Law Journal has a great article titled Attorneys Angered Over Lack of IRS Aid which tells about the IRS’s failure to efficiently and properly evaluate and process Offers in Compromise and Partial Payment Installment Plans: At the start of the new year, the Internal Revenue Service announced steps to help struggling taxpayers buffeted by [...]
Tags: IRS Installment Agreements · Offers in Compromise · Taxpayer Advocate
Preparing the IRS Financial Statement: Do’s and Don’ts
February 12th, 2009 · 1 Comment
If you can’t pay your tax debt in full, you will have to completely disclose your financial circumstances to the IRS. There is no way to avoid this disclosure requirement other than making full payment. A taxpayer’s financial information is provided on one or more of the following prescribed IRS forms: IRS Form Number Description [...]
Tags: IRS Installment Agreements · Offers in Compromise · Tax Collections
Taxpayer Advocate’s Recommendation: Go Easier on Taxpayers Experiencing Economic Hardship
January 11th, 2009 · 4 Comments
Nina Olson, the National Taxpayer Advocate, has released her Annual Report to Congress (PDF). In it she recommends something old and something new: Simplification of the tax code and enactment of measures that will minimize the burden on taxpayers who are struggling to pay their tax bills. Ms. Olson said, “it is imperative for the IRS to consider the circumstances of [...]
Tags: Announcements · Back Taxes · IRS Installment Agreements · IRS Liens and Levies · Offers in Compromise · Tax Collections
Tax Court Update – December 2008 – Common Law Contract Rules Apply to Offers in Compromise
December 22nd, 2008 · No Comments
David W. Trout v. Commissioner of Internal Revenue - In 1997, the taxpayer entered into an offer-in-compromise (OIC) with the IRS covering tax years 1989, 1990, 1991, and 1993. The OIC included a term that required the taxpayer to timely file and pay his taxes for the next five years. The taxpayer filed his 1996 tax return [...]
Tags: Back Taxes · Court Cases · Offers in Compromise
IRS Announces New Mediation Program for Offers in Compromise and Trust Fund Recovery Penalties
December 11th, 2008 · 1 Comment
In IR-2008-135, issued on Dec. 1, 2008, the IRS announced its institution of a 2 year test of the post-Appeals mediation and arbitration procedures for Offers in Compromise (OIC) and Trust Fund Recovery Penalties (TFRP). Beginning Dec. 1, 2008, for a two-year test period, IRS Appeals will offer post-Appeals mediation and arbitration for OIC and TFRP [...]
Tags: Announcements · Offers in Compromise · Payroll Taxes · Trust Fund Recovery Penalty
Tax Court Update – November 2008 – Offers In Compromise and IRS Abuse of Discretion
December 7th, 2008 · No Comments
Leslie B. Bennett v. Commissioner of Internal Revenue – This case demonstrates how difficult it can be to get the IRS to accept an Offer in Compromise. The Petitioner, Ms. Bennett, owed $110,000.00 to the IRS. She filed an Offer in Compromise offering $15,000.00 in complete and total settlement of the debt. The IRS rejected the [...]
Tags: Court Cases · Offers in Compromise







