Tax Seminar #3 – December 3 2012

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E. MARTIN DAVIDOFF ATTORNEY AT LAW 353 Georges Road - Suite K P.O. Box 835 Dayton, NJ 08810-0835 EMD@taxattorneycpa.com _____________ TEL: 732-274-1600 FAX: 732-274-1666 December 20, 2005 VIA CERTIFIED MAIL #70050390000151327296 Mrs. S. Lopez Internal Revenue Service 100 Dey Place Edison, NJ 08817 Re: Whitey & Joan Ford SS#s: 123-45-6789 & 987-65-4321 Forms 1040: 1997 through 2003 Dear Mrs. Lopez: I am in receipt of your letter dated December 6, 2005 rejecting our request for penalty abatement for the years 1997 through 2003 for the above-nam ed Taxpay ers. Please note that we wish to receive further consideration by an Appeals Officer. In regard to that, I am providing you the following information: 1. I would like to appeal your findings. 2. The name and address of the Taxpayer(s) is: Whitey and Joan Ford 123 Main Street Anywhere, New Jersey 08666 3. The outstanding facts supporting our position are included in our letter to you of October 31, 2005, a copy of which is attached to this letter. Under the penalty of perjury, I declare that the facts presented in the accompanying statement are, to the best of my knowledge and belief, true, correct, and complete. Thank you very much for your attention to this matter. Very truly yours, Encl. cc: Mr. and Mrs. Whitey Ford (w/out encl.) E. Martin Davidoff 112
E. MARTIN DAVIDOFF ATTORNEY AT LAW 353 Georges Road - Suite K P.O. Box 835 Dayton, NJ 08810-0835 EMD@taxattorneycpa.com _____________ TEL: 732-274-1600 FAX: 732-274-1666 January 5, 2009 VIA FEDERAL EXPRESS Internal Revenue Service Attn: E:3:SF:30 44 S Clinton Avenue Station Plaza #3 Trenton, New Jersey 08609 [See Publication 3498] RE:John Doe Taxpayer ID# 123-45-6789 Form 1040: 2005 To Whom It May Concern: We hereby protest certain findings of the examining agent set forth in the thirty-day letter dated December 14, 2008 and the accompanying examination report attached hereto, the response to which has been extended by James E. O’Hara until February 6, 2009. 1. Statement of Appeal We wish to appeal such findings to the Office of the Regional Director of Appeals and we request a conference in that office. 2. Name, Address and Daytime Phone Number John Doe 123 Main Street Anywhere, New Jersey 08876 Taxpayer ID# 123-45-6789 Daytime Telephone Number: Please note that the Taxpayer is represented by me and I may be reached at 732-274-1600. In my absence, Fanny Mae, my paralegal, is familiar with the case and will be in a position to schedule specific times for an appeals officer to speak with me. 3. Date and Symbols of Transmittal Letter The date and symbols of the letter transmitting the proposed adjustments are as follows: August 14, 2008 Refer Reply to: E:1403:30:SF Letter 950(Rev 2-2008) 113
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The Zicklin Tax Seminar Series Tax
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E. MARTIN DAVIDOFF & ASSOCIATES CER
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• Payments of more than 24 months
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Reduced Offers Examples: One of the
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2 If you have any questions, please
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FACTS OFFER IN COMPROMISE CASE STUD
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Form 433-A (OIC) (Rev. May 2012) Us
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Section 3 (Continued) Cash value of
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Section 5 Business Income and Expen
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Section 8 Other Information Page 7
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L:\EMD\433Case11:B Personal Liabili
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433CASE12.123 John & Jane Doe 08/17
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Form 656 (Rev. May 2012) Department
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Section 6 Designation of Down Payme
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Form 656 (Rev. May 2012) Department
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Jim and Kelly Smith SS#: 123-45-678
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Offer In Compromise Package Logisti
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New Jersey - Local Standards: Housi
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One Car Two Cars Houston $312 $624
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Print Email Reports Export Reports
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Internal Revenue Manual - 5.8.5 Fin
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Internal Revenue Manual - 5.8.5 Fin
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E. Martin Davidoff - Offer in Compr
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Form 656 Booklet Offer in Compromis
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an offer unless the trust fund port
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Step 2 - Fill out the Form 433-A (O
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Section 2 Business Asset Informatio
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Page 4 of 6 Section 3 Business Inco
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Section 7 Signatures Page 6 of 6 Un
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LIEN HAS BEEN RELEASED 163
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617-316-2608 617-316-2606
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Online Payment Agreement Applicatio
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OUTDATED 171
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October 2011 Your Access to Free Cr
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FTC Facts For Consumers 3 access it
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FTC Facts For Consumers 5 or an unp
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Identity Theft 1. Example scenarios
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The Zicklin Tax Seminar Series IRS
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Notice and Demand of Tax Due • Th
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Unfiled Lien v. Filed Lien A filed
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Collection Appeal Rights Process
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IRS Appeals Can Also Help After the
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To Stop an IRS Levy • Resolve the
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How to File a CDP Request • Compl
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I. How Does A Tax Debt Arise? AGOST
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d G. 3 Notice - “Immediate Action
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3. If case is not assigned to the l
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payments. The only other asset is t
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(2) The Trust fund portion of the t
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Department of the Treasury - Intern
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Instructions for completing Form 91
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Collection Appeal Request (Instruct
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Request for a Collection Due Proces
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Information You Need To Know When R
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The Zicklin Tax Seminar Series IRS
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IRS Tax Collections: Liens and Levi
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Treasury Department Circular No. 23
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Table of Contents Paragraph 1. . .
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Paragraph 1. The authority citation
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of section 404(a) (2)), 404 (relati
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(1) The former employee applies for
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This notification must include the
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software, taxation, or ethics); and
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the matter within 60 days of the da
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otherwise prescribed in forms, inst
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Subpart B — Duties and Restrictio
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a rule with respect to that particu
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in writing by each affected client,
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(ii) Advise a client to take a posi
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(5) Marketed opinion — (i) Writte
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under paragraph (e) of this section
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their practice with the firm, that
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paragraph (a) of this section. (ii)
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§ 10.53 Receipt of information con
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as determined under section 6212 of
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and law in support. (2) Summary adj
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specifically provided for in this s
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§ 10.73 Evidence. § 10.74 Transcr
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the Secretary of the Treasury, or d
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to a conference and may be suspende
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Tax Seminar #3 – December 3 2012

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