Tax Seminar #3 – December 3 2012

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Alternatives to Immediate Full Payment • Taxpayer may: – Call the IRS and request 120 days reprieve from IRS notices to obtain funds to full pay the tax due – Request an installment agreement, offer in compromise – File for bankruptcy 7 Collection Tools: Notice of Federal Tax Lien Filing & Levy • Notice of Federal Tax Lien – “If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, additional amount, addition to tax, or assessable penalty, together with any costs that may accrue in addition thereto) shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.” IRC §6321 8 186
Unfiled Lien v. Filed Lien A filed tax lien is one that has been filed in the appropriate county or state records to put third parties on notice of the IRS’s claim so as to protect the IRS from the claims of parties who reasonably could have been on notice of the IRS’s lien by checking the records. 9 Notice of Federal Tax Lien Filing • The Notice of Federal Tax Lien (NFTL) filing is a public filing and can have a detrimental effect on the taxpayer’s credit and business reputation. 10 187
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The Zicklin Tax Seminar Series Tax
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E. MARTIN DAVIDOFF & ASSOCIATES CER
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5
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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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Rules of Engagement in Dealing With
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Rules of Engagement: Dealing With I
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IRS Rules of Engagement: Under Prom
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Dealing with the IRS Regarding Coll
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I R S R E P R E S E N T A T I o N A
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R.C.P. OLD NEW Monthly Excess $361
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R.C.P. - Example #1 OLD NEW Monthly
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May 21, 2012 OIC Rules • There wi
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May 21, 2012 OIC Rules • State an
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May 21, 2012 OIC Rules Substantial
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Steps in a Controversy 1. Initial c
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Alternatives in a Collection Matter
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E. MARTIN DAVIDOFF ATTORNEY AT LAW
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Mr. & Mrs. Mickey Mantle January 5,
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Form 2848 (Rev. 3-2012) Page 2 6 Re
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Excerpts from the Internal Revenue
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Sample Status Sheet GOALS of Johnny
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6. Request for a Collection Due Pro
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Information You Need To Know When R
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Collection Appeal Request 1. Taxpay
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John J. and Jane Doe Form 9423 Coll
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experience is that we secure better
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Department of the Treasury - Intern
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Mr. William Skowron December 12, 20
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Form 9465-FS (12-2011) Page 2 Part
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INSTRUCTIONS TO TAXPAYER If not alr
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Mr. Yogi Berry September 19, 2011 P
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Mr. Jeffrey Austin January 5, 2011
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Texas Iowa, Kansas, Louisiana, Miss
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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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