Tax Seminar #3 – December 3 2012

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Notice of Federal Tax Lien 11 Requesting a Collection Appeals Hearing Can Delay or Stop the Lien Filing • Request a conference with the revenue officer to request delay or forbearance • If revenue officer denies request, request a conference with the group manager (required within 24 hours) • If group manager denies request, file a Collection Appeal Request (CAP) (Form 9423) with two (2) days pursuant to the Collection Appeal Program – Pub. 1660 • Present your case to the Appeals Office – This is your last chance to delay or avoid Notice of Federal Tax Lien 12 188
Collection Appeal Rights Process • The following publications and forms explain appeal rights and provisions: – Pub 594, The IRS Collection Process – Address general appeal provisions – Pub 1660, Collection Appeal Rights – Provides detailed info regarding Collection appeal rights and procedures under CDP and CAP. – Form 9423, Collection Appeal Request – Form 12153, Request for Collection Due process or Equivalent Hearing – Used to request CDP/ Equivalent Hearing 13 IRS’s Fresh Start Program • The IRS announced on Feb 24, 2011 a series of new steps to help people get a fresh start with their tax liabilities. • Changes include: – Significantly increasing the dollar threshold when liens are generally issued – Making it easier for taxpayers to obtain lien withdrawals after paying a tax bill – Withdrawing liens when taxpayer enters into Direct Debit Installment Agreement – Easier access to installment agreements for small businesses – Expanding streamlined Offer in compromise program. • See IR-2011-20, 2/24/11 14 189
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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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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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4. Filing of Tax Court Petition In
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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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