Forgotten Offer in Compromise Extended IRS Collection Time

Houston Tax Attorney

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Sometimes it is best to wait for the IRS’s collection statute to expire. This is a wait-and-see approach where the taxpayer waits to see if the IRS attempts to collect the tax debt. To succeed, it is important for the taxpayer to not extend the IRS’s collection statute. This issue came to a head in […]

Discharging Taxes in Bankruptcy vs. Settling with the IRS

Houston Tax Attorney

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Bankruptcy can be one of the best methods for resolving tax debts. This is particularly true if the taxpayer’s primary assets only consist of retirement accounts and equity in a personal residence. The recent In re Moore, No. 15-42046 (Bankr. E.D. Tex. Jul. 7, 2016), case presents an opportunity to consider the results if the […]

IRS Did Not Err in Rejecting an Informal Offer in Compromise

Houston Tax Attorney

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In Bergdale v. Commissioner, T.C. Memo. 2014-152, the U.S. Tax Court concluded that the IRS did not abuse its discretion in rejecting an offer-in-compromise that was not submitted on a Form 656, even though it appears that the IRS and the taxpayer may have tentatively reached an oral agreement to settle the tax debt. The […]

Offer in Compromise Rejected Where Records of Household Member Not Provided

Houston Tax Attorney

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In Winters v. Commissioner, T.C. Memo. 2012-183, the U.S. Tax Court concluded that the IRS correctly rejected an offer in compromise submitted based on doubt as to collectibility based in part on the taxpayer not providing records to establish the income of a person who resided in his home. The facts and procedural history are […]

Offer in Compromise in Amount Less Than Value of Assets Not Accepted

Houston Tax Attorney

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In Wright v. Commissioner, T.C. Memo. 2008-259, the U.S. Tax Court concluded that an offer in compromise based on doubt as to collectibililty in the amount of $2,000 was properly rejected when the value of the taxpayer’s assets was $3,000. The court reached this conclusion even though the IRS may have erred in computing the […]

Offer in Compromise: The Coming Storm?

Houston Tax Attorney

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The Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA) makes substantial changes to the IRS offer in compromise program. Most notably, TIPRA includes a provision in which taxpayer submitted offer in compromises are “deemed” accepted by the IRS. The offer in compromise or OIC program for compromising tax debts for less than is actually […]