Trust Fund Recovery Penalty

Section 6672 of the Internal Revenue Code allows the IRS to hold “willful and responsible” individuals within a business organization personally liable for the business entity’s unpaid trust taxes. Trust taxes include some federal excise taxes (most businesses are not subject to pay federal excise taxes). By far the most […]

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Accounts Receivable Levy

After procedural requirements have been fulfilled by the IRS, it may issue a Notice of Levy (Form 668-A) to the accounts receivable of a delinquent taxpayer.  The Notice of Levy requires the receivable to send any payment to which the delinquent taxpayer has a fixed and determinable right directly to […]

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Asset Seizure (a.k.a. Levy on Asset)

After procedural requirements have been fulfilled by the government, it may levy (seize) non-exempt assets of a delinquent taxpayer.  The government takes physical possession of the asset and will typically sell the asset at an auction and apply the proceeds to the taxpayer’s tax liability.  State taxing authorities generally follow […]

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Bank Levy

After procedural requirements have been fulfilled by the IRS, it may issue a Notice of Levy (Form 668-A) to a bank that holds funds belonging to a delinquent taxpayer.  The Notice of Levy requires the bank to freeze any funds that are in the taxpayer’s account at the time the […]

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Notice and Demand for Payment

Before the IRS may file a Notice of Federal Tax Lien, it must first issue a Notice and Demand for Payment to the taxpayer and wait at least 10 days before filing a Notice of Federal Tax Lien (assuming the taxpayer does not pay off the tax liability within those […]

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Installment Agreements

An Installment Agreement is a written agreement between a delinquent taxpayer and the IRS which requires the taxpayer to make periodic (typically monthly) payments to the IRS.  The IRS will not enforce (levy) against a taxpayer for tax liabilities that are covered by an installment agreement that is in good […]

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Offer in Compromise

An Offer in Compromise (OIC) is a formal, written agreement between a taxpayer and the IRS to settle a tax liability for less than the full amount owed.  Many states have a similar program.  An OIC can be based on “Doubt as to Collectability” (the taxpayer proves he or she […]

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Can my tax liability be reduced?

Some taxpayers qualify for an Offer in Compromise (a tax settlement), while others may qualify for an abatement (reduction/elimination) of penalties.  Others qualify for a Partial Payment Installment Agreement, which technically does not reduce the debt, but can have the effect of having the taxpayer repay less than the full amount due.  There […]

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What types of tax professionals can represent me with my back tax liability, and which type is best for my situation?

Enrolled Agents, CPAs, and attorneys have unlimited authorization to represent taxpayers before the IRS.  Since resolving most tax collection cases has little to do with number crunching, and a lot to do with building and presenting a strong case, we believe that the skill set of an attorney experienced in […]

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Do I need a local tax representative?

No. We have heard countless horror stories about taxpayers who have hired a local CPA, Enrolled Agent or attorney to represent them for a tax collection case.  Poor customer service, crummy results, and a lack of expertise dealing with tax collection cases are commonly cited problems.  Few local accountants and […]

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What is the difference between a lien and a levy?

A lien is a secured interest in an asset or assets.  A Notice of Federal Tax Lien is a public record which notifies the world that a taxpayer owes taxes, and places a public claim against the assets of the taxpayer.  A lien can affect a taxpayer’s credit, and can […]

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What are your guarantees?

We guarantee that your case will be personally handled by a licensed attorney from start to finish.  You can try us out without any obligation whatsoever.  After completing our easy intake paperwork, your case will be assigned to one of our attorneys.  If you do not wish to continue for […]

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