[Tax Controversy]

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accountancy • tax services • consulting

Tax Controversy “For those who need it department" (1 of 3)

Tax Problems? Not sure what you have? Ask me! Past due returns our specialty!
When the IRS slows you down, there are two things you want...
1. You want them to stop, and
2. You want them not to come back.
  - No need to talk to the IRS on the phone, we will negotiate for you.
Every taxpayer is entitled to representation.
- A taxpayer may represent oneself, or
  - With a properly signed written authorization, Form 2848 Power of Attorney and Declaration of Representative, have a representative, who is an individual authorized to practice before the IRS, e.g. Attorney, Certified Public Accountant (CPA), or Enrolled Agent (EA), represent him/her/X-gender. Ordinarily, it is not required to research the status of a representative. However, you may choose to verify a representative’s eligibility at Directory of Federal Tax Return Preparers with Credentials and Select Qualifications.
Is the IRS getting too much of your money?
- If you are like most people, you find the job of keeping accurate tax records is a burdensome chore. We have a supergreat accountant that can show you how to significantly reduce your tax burden as well as protecting your assets without driving you crazy.
- We will provide to you, at no obligation whatsoever, a free 30 minute confidential review and analysis of your individual and/or business taxes for the purpose of recovering tax money paid, and protecting your future income and all assets.
  - The majority of income tax returns today need additional professional assistance in accomplishing the task of preparing the necessary complicated forms and schedules such as employee business expense, a home sale or purchase, capital gains on stock or other asset sales, retirement income, rentals, as well as many, many others.
- Now, there is a convenient and low cost way to keep track of your tax deductible expenses without driving you insane. I would be happy to provide you with information about record keeping at no obligation to you.
  - Would you please give me your name, and your home or work telephone number and the best time to reach you there. I think you will be impressed at the low cost of this service and the savings you will receive.
  - Please call me to set up a free consultation at your office or mine. The number is (603) 508-0124 ask for "Steve" Stephen B. Jordan. EA
The requirement to file an income tax return is explicitly stated in §§6011(a), 6012(a), and 6072(a) and corresponding Treasury Regulations. In addition, §6151 requires taxpayers to submit payment of their taxes with their tax returns.
- All taxpayers are expected to immediately full pay delinquent tax liabilities. When this is not possible, taxpayers may be allowed to pay their liabilities over a prescribed period of time. If full payment cannot be achieved by the Collection Statute Expiration Date (CSED), and taxpayers have some ability to pay, the Service can enter into a Partial Payment Installment Agreement (PPIA). The American Jobs Creation Act of 2004 amended IRC §6159 to provide this authority.
- “Partial Payment” means partial payment of the total amount due.
- Check out this part of the IRM 5.14.2.2 (04-26-2019)
- The CSED refers to the last date the IRS can collect on a debt – generally, ten years from the date of assessment. If you file a tax return, the date of assessment is the date the IRS processes the tax return and posts it to your Individual Master File (IMF) account for that year. Thus, if the latest assessment date for the years covered by your installment agreement is sometime in year 2020, the CSED should be in 2030 – ten years from now .
- A PPIA can not be approved by the IRS without an evaluation of your finances. Usually, this means you have to complete Form 433-A, the Collection Information Statement. (See IRM 5.14.2.2.1(1).)

In-Person Tax Help

Solving tax problems - Federal & State. Past due returns our specialty. Late filers, tax lien & levy assistance, installment agreements, payment plans, offers-in-compromise, audits & appeals, Collection Due Process (CDP), innocent spouse.
If your tax return is prepared by the IRS (Substitute For Return - SFR) under §6020(b) the statute of limitations on assessment and collection shall not apply. §6501(b)(3) Rev. Reg. §301.6501(b)-1(c).
SFR's are NOT dischargeable in Bankruptcy. In re Forrester case: Even though the IRS prepared Forrester's Substitute for Returns (SFRs) prior to Forrester's filing for bankruptcy, the Bankruptcy Court held that, under Title 11 USC §523(a)(19), IRC §6020(b) SFRs were not “returns” for the bankruptcy period.
IRS Policy Statement 5-133, Delinquent Returns – Enforcement of Filing Requirements, states taxpayers must file six (6) years of back-tax returns to be in good standing with the IRS. IRM 4.12.1.3.1 (10-05-2010) states IRS management must approve any deviation from the 6-year rule.
IRM 4.12.1.5.4 (10-05-2010)
- Statute Considerations...
  - (2) The execution of a substitute for return does not trigger the running of the assessment (ASED) or collection (CSED) statutes. See IRM 25.6.1.9.4.5, Substitute for Return (SFR).
IRM 25.6.1.9.4.5 (10-05-2016)
- Substitute for Return (SFR)
  - (1) Under authority of IRC §6020(b), the Service has authority to prepare and process a tax return when a person fails to file a required return or files a false or fraudulent return.
  - If the Service processes a tax return prepared under the authority of §6020(b), assessing the tax accordingly, the assessment date (ASED) will start the period for the statute of limitations for collection (CSED) per §6502(a)(1), but does not start the period of limitations for assessment (ASED) per §6501(b)(3).
  - (2) If the taxpayer signs a SFR return prepared from income information received from the taxpayer, it becomes the taxpayer’s return per IRC §6020(a) and starts the assessment period of limitations.
- If the taxpayer "signs" a Waiver of Restriction on Assessment (Form 870, 4549, etc.), it does not constitute a return under §6020 (a), in accordance with Rev. Rul. 2005–59.
- If the Service has processed an unsigned Substitute for Return (SFR), the taxpayer may still file a signed tax return for the same tax year as the SFR return. The assessment statute (ASED) period for that tax year will begin with the received date of the taxpayer’s signed return. See §6501(a)and(b)(3).
- Note: If the Service collects tax payments or if the taxpayer sends in payments beyond the Collection Statute Expiration Date (CSED), the taxpayer may be legally entitled to a refund per §6401(a) and §6402.
  - The taxpayer would not be entitled to a refund of these amounts if the taxpayer owes other unpaid liabilities for the same tax period that equal or exceed the amount of the payments or the taxpayer's claim for refund of these amounts is barred under other code provisions.
  - The taxpayer is not legally entitled to a refund if the payments were made pursuant to a fixed and determinable levy that predates the CSED.
We are a one-stop resource for face-to-face tax help and solutions to tax problems, every business day. Get help solving federal tax problems. We only ask you make an appointment by calling our office at (603) 508-0124 and leaving a message if necessary.
We can help you:
- File innocent spouse claims if you believe you are not liable for your spouse's share of a joint liability
- Make an installment agreement if you cannot pay your taxes in full
- Prepare an Offer-in-Compromise to settle an unpaid tax debt
- Request a release of federal tax liens and levies when appropriate
- Resolve IRS account & notice issues
Other services include:
- Answers to your tax questions
- Information about your tax account (IRS Power of Attorney necessary)
- Help to prepare your individual income tax return
- Help to prepare your heavy use vehicle tax return
Call our office at (603) 508-0124 today to find out if you qualify for an Offer or Payment arrangement.
- Need help from a tax professional but can’t afford one? AGI < $29K? You may be eligible for assistance from an LITC
  - We do legitimate offers! We will not accept one dime unless you pre-qualify. We're here to do whatever is in our client's best interest.
Tax Defense Network: Your IRS Tax Relief Experts
Federal Tax Collection Rules & Procedures - Internet Resource Links
- Chief Counsel Notices
- Chief Counsel Bulletins
- Collection Due Process
- Criminal Tax Manual (DOJ)
- FOIA-Guidelines
- Freedom of Information Act (FOIA.gov)
- Injured/Innocent Spouse Relief
- Innocent Spouse, IRS self-help tool & information
- Installments, IRS self-help tool & information
- Internal Revenue Code
- Internal Revenue Manuals
- IRS Audits & Appeals
- IRS Forms
- IRS Publications
- IRS Reading Room (notices, CCA, training material, etc.)
- Offer-in-Compromise "reasonable collection potential" (RCP)
- Offer in Compromise Pre-Qualifier online tool
- Payroll Tax Problems
- Penalty Abatement IRS Form 843 – Claim for Refund and Request for Abatement
- Penalty & Interest Abatement ("reasonable cause" must be present)
- Treas. Regulations
- US Attorney Manuals, index
- Wage Garnishments
Taxpayer Representation - resolving tax liabilities

Options
- Full Pay
- Payment plan
- OIC - Equity
- CNC - Debt doesn't go away (Currently Not Collectible - "Code 53")
Attorney referrals to discharge taxes in bankruptcy for certain exceptions.
Tax lien & levy assistance - bank account levies/garnished wages
Partial Payment Installment Agreement (PPIA) §6159 (affordable monthly payment plan)
Expanded administrative appeals in many dispute areas.
Injured spouse relief §6015(b):
- Form 8857 (Request for Innocent Spouse Relief)
Separation of liability relief - innocent spouse §6015(c):

Tax Controversy “For those who need it department" (2 of 3)

Tax (debt) Resolution Pricing

Bronze $250 "Wage Earner" (W-2) Levy Release flat fee will STOP your Wage Garnishment (if "financial hardship" exists) in as little as 4 business days. Our flat fee to represent you as Power of Attorney (POA) before the IRS is $500. Fee includes Levy and/or Wage Garnishment release (if "financial hardship" exists). Fee includes implementation of Partial Payment Installment Agreement (PPIA), potential Penalty Abatement, Injured/Innocent Spouse Relief, Installment Agreement, Offer-in-Compromise (OIC) and/or having you listed as Currently Not Collectible (CNC) by the IRS.
Silver $1,500 Full Service If your tax debt is less than $100,000 our flat fee to represent you as Power of Attorney (POA) before the IRS is $1,500. Fee includes Levy and/or Wage Garnishment release (if "financial hardship" exists), potential penalty abatement, Injured/Innocent Spouse Relief, Installment Agreement, Offer-in-Compromise (OIC) and/or having you listed as Currently Not Collectible (CNC) by the IRS.
Gold $2,000 Full Service If your tax debt is more than $100,000 our flat fee to represent you as Power of Attorney (POA) before the IRS is $2,000. Fee includes Levy and/or Wage Garnishment release (if "financial hardship" exists), potential Penalty Abatement, Injured/Innocent Spouse Relief, Installment Agreement, Offer-in-Compromise (OIC) and/or having you listed as Currently Not Collectible (CNC) by the IRS.
Platinum Fee (to be determined) after we complete a tax debt analysis of your case. If your tax debt is more than $1,000,000 our flat fee to represent you as Power of Attorney (POA) before the IRS to be determined after we complete your tax debt analysis. Fee will include Levy and/or Wage Garnishment removal (if "financial hardship" exists), potential Penalty Abatement, Injured/Innocent Spouse Relief, Installment Agreement, Offer-in-Compromise (OIC) and/or having you listed as Currently Not Collectible (CNC) by the IRS.
To obtain a permanent reduction in your tax debt, it's not enough to show the IRS that you can't pay your tax bill. You must also prove you've exhausted all of your financial resources and have little hope of raising money in the future.
Haven't Filed in a While?
- Owe Money to the IRS?
  - Now What?
    - We Can Help You!
      - We do legitimate offers!

Offer in Compromise Pre-Qualifier online tool

This online tool can be used to determine if a taxpayer is eligible for an Offer in Compromise (OIC). If the taxpayer is eligible for an OIC they must still complete and submit a Form 656 and a Collection Information Statement (Form 433-A). The tool brings the user (the practitioner or the taxpayer) through six steps:

Status: This step contains questions to determine the taxpayer’s eligibility for an OIC.
Basic info: This step contains questions regarding the taxpayer’s location and their tax debt.
Assets: This step contains questions regarding the taxpayer’s assets (FMV and any encumbrances).
Income: This step contains questions regarding gross wages, net business and rental income, and other sources of income.
Expenses: This step requests information regarding the taxpayer’s necessary living expenses. The tool will consider the local allowable expense criteria for the taxpayer.
Proposal: In this step, the tool will suggest a starting point for the offer amount representing the sum of asset equity and the present value of future income.

The taxpayer or their authorized representative should use the results from the OIC Pre-Qualifier to complete the required forms in the OIC booklet. If the suggested amount cannot be offered, a lower amount could be justified if the taxpayer has qualifying exceptional circumstances (Section 3 of Form 656).

Has it been awhile since you filed a tax return?

Feeling guilty? Scared?
Don't know what to do or where to turn?
Past Due Taxes Are a Serious Problem!!
Do you even need to file? Yes.

Tax Resolution • Tax Problems? Past or Present... Your 1st step to solving these problems is calling our office. We will help you with the following:

File un-filed returns
Handle all negotiations with the IRS for you
Prepare past due returns
Evaluate CNC status, and implement if appropriate (for people having an "economic hardship")
Negotiate an affordable monthly payment plan with the IRS
Settle your tax debt with the IRS for your reasonable collection potential (RCP)
Wage Garnishment/Bank Levy Release (within 4 days)
Discharge tax liens from your credit and property (if debt is settled)
Our service is not over when your crisis is over. As tax specialists, we can prepare your prior and present year returns; keeping you current, to avoid a similar occurrence in the future. We will prepare financial statements and help you set realistic goals for repayment. We help create a long-term plan for future success.
Attorney referrals to discharge taxes in bankruptcy for certain exceptions

Volunteer

If you come forward and voluntarily file your missing tax returns, the system works more in your favor. Since nearly three out of four tax returns filed are due a refund, there is a good chance that the IRS might owe money to you. The only catch is that if you don't ask for your refund within three years, the IRS isn't going to give you what was yours in the first place. We are available to help you file your returns and, if necessary, act as your representative before the IRS. We work for you, not the IRS. Sometimes things just happen. If there is a good reason for not filing a tax return, some of the penalties can be reduced. Generally, if the IRS owes you a refund there are no penalties at all.

Scared of Volunteering?

If the IRS decides to come looking for you, life can become very difficult and frequently embarrassing. There is a chance that your employer might be requested to send part of your paycheck to the IRS instead of handing your paycheck to you. Your bank account could be frozen or even seized. A lien could be placed on your house. In the worst case, you could face criminal prosecution.

What if you owe money?

Installment Agreements -- If you can pay the full amount within five years, you should be able to set up a monthly payment plan and make regular installment payments. The IRS is now accepting Partial Payment Installment Agreement (PPIA).

What if you owe a lot of money?

Offer in Compromise -- If you owe so much money that you will never be able to pay your tax liability, we may be able to work out a compromise where the IRS will accept less than you actually owe. If the IRS accepts your Offer-in-Compromise (OIC), your total tax liability including interest and penalty is considered paid in full. An OIC is a mathematical formula, NOT an amnesty program. Professional assistance is strongly recommended when compromising a tax liability. Professional assistance. Don't be afraid to ask for help. By law, you have the right to professional representation. Only an Enrolled Agent, certified public accountant or attorney can represent your case before an IRS Collections Officer. Remember, your representative is working for you. The IRS has ten (10) years from the date of a tax assessment to collect a debt from the taxpayer.
The date the collection statute expires is called the Collection Statute Expiration Date or CSED. §6502 provides that the length of a period for collection after assessment of a tax liability is ten years.
When the CSED date passes, the IRS is barred from attempting to collect your tax debt unless you waive the enforcement of the statute.

When Does the Collection Statute Start to Run?

The statute starts on the day an IRS assessment is made.
Generally, the dates of assessment are as follows:
- Filed tax returns – The date you mailed the tax return plus six weeks.
- Audit Adjustments (agreed) – The date you signed the auditor’s report plus three weeks.
- Audit Adjustments (unagreed) – The date the appeals process and the tax court process (if any) is completed and the tax court judge has issued his or her ruling.

What Will Cause the Collection Statute to be Extended?

The Collection Statute can be extended (tolled) by one or more of the following acts or situations:
- The filing of a bankruptcy petition - The statute is extended for the duration of the bankruptcy proceedings.
- The filing of an Offer in Compromise - The statute is extended for the duration of the Offer or one year, whichever is greater.
- The filing of requests for relief – The statute is extended when taxpayer files for a Collection Due Process (CDP) hearing, Innocent Spouse Relief and any other form of relief that requires the IRS to suspend collection enforcement while it reviews the validity of the underlying assessment.
- The signing of a waiver extending the statute - The statute is extended to date indicated in a signed waiver. Never sign a statute extension without first consulting your tax advisor.
- The taxpayer is out of IRS jurisdiction – The statute is extended for duration taxpayer was out of IRS jurisdiction.
Example: 10-year period begins to run with the date of the “assessment,” not the tax year for which taxes are due. For example, if the return for 2015 is not filed until 2018 and the tax is assessed in 2019, the 10-year period begins to run in 2019 and expires in 2029. Ten years is not always the limit. There are a number of other ways the 10-year collection period may be extended. For example, during the period an Offer in Compromise is pending, the statute of limitations is extended accordingly. Similarly, if bankruptcy is declared, while the bankruptcy proceeding is pending, the 10-year statute of limitations on collection is extended by the duration of the bankruptcy proceeding.
Court action may suspend the running of the 10 years. The filing of an IRS levy or a judgment entered in a Federal Court in a suit by the Department of Justice can also extend the 10-year period. The IRS can ask the Department of Justice to institute a collection proceeding in Federal District Court. If such a proceeding is begun and the United States Government prevails, then the statute of limitations on collection on that judgment is extended for the period generally allowed to collect such judgments, and such judgments can be renewed subject to the discretion of the Court.

What options are available to me to solve my tax problem?

Currently Not Collectible (CNC) Hardship - When the taxpayer cannot afford to pay the IRS monies due to a lack of assets and low income or no income (e.g. recently laid off due to current economy, divorce, illness) then the IRS will deem the taxpayer Currently Not Collectible (CNC) "Code 53" and agree the tax liability will be suspended for the time being.
Installment Agreement (§6159) - A monthly payment plan set up to pay back the taxpayer's tax liability. The IRS has guidelines as to what amount they will accept and the time frame they will accept it in (usually sixty months). A financial affidavit (Form 433-A) is required from the taxpayer before we can negotiate an installment agreement. Under an installment plan, you make monthly payments on your tax debt for up to six years (72 months). This is something you can do on your own. The IRS fee to set up an installment plan is $225 (Online $149), or $107 ($31 Online) if you agree to have payments automatically debited from your bank account. Approval is automatic for taxpayers who owe $50,000 or less and are in good standing with the IRS. Reinstated I/A fee is $89. Low-income I/A fee is $43.
Offer in Compromise (§7122) (We do legitimate offers!) - An offer to the IRS to lower the total tax liability owed by the taxpayer due to financial constraints. This is a very popular solution advertised on TV. Under the offer program, the IRS agrees to accept less than you owe. But to obtain a permanent reduction in your tax debt, it's not enough to show the IRS that you can't pay your tax bill. You must also prove you've exhausted all of your financial resources and have little hope of raising money in the future
Penalty Abatement - The IRS assesses penalties and interest on tax liabilities so over time taxes due years ago can increase from hundreds to thousands of dollars. The IRS will sometimes lower or eliminate these fees with a well worded request. The IRS won't grant penalty abatement without reasonable cause. For example, a widow who filed her tax return late because her husband died shortly before April 15 might qualify for penalty abatement. If you believe you can show extenuating circumstances, you can apply on your own or ask your tax preparer to file a request on your behalf.
Wage Garnishment/Bank Levy Release - The IRS will collect their monies due by any means necessary. They may take all your assets with a levy or garnish up to 70% or your wages. We can negotiate with the IRS to have these released in as little as 4 business days.
Audit Representation - If you are currently being audited and you don't know why, it is very important to be represented by a tax professional who can get to the bottom of the problems and fix them. We can have your past audit reopened if you feel you did not get a fair shake.
I have unfiled taxes from previous years but no longer have my records from those years. Can you help me? We can prepare your past unfiled tax returns by requesting your IRS wage transcripts and completing a tax questionnaire.
Is there anything I need to do before I can solve my tax problems? Before the IRS will accept any negotiations to solve your tax liability you will need to be in compliance with any unfiled tax returns. Any unfiled taxes up to ten years ago may be required to be prepared and filed with the IRS.

If you owe the IRS money, you have options:

Find an EA

Talk to an Enrolled Agent who has experience dealing with IRS collection issues. If you already have a tax preparer, he or she may be able to help you or refer you to someone who can. In a clash with the IRS, don't be unarmed. Defend yourself with cutting edge tax knowledge and the shield of confidence provided by an Enrolled Agent. You would not go into battle without a weapon, or court without a lawyer. Don't try to negotiate successfully with the IRS without and Enrolled Agent (EA) to represent you. EA's are admitted to represent you before the IRS. Call us your "TAXPAYER ADVOCATES!"

If you can't afford to hire a tax professional, you may qualify for a Low-Income Tax Clinic. To find one near you, go to the website for the IRS Taxpayer Advocate or call 877-777-4778

Tax Controversy “For those who need it department" (3 of 3)

Call us your TAXPAYER ADVOCATES!

★ Haven't Filed in a While?

★ Owe Money to the IRS?

★ Now What?

★ We Can Help You!

★ We do legitimate offers!

Taxpayer Representation Pricing:

Bronze $250 "Wage Earner" (W-2) Levy Release Flat fee will STOP your Wage Garnishment (if "financial hardship" exists) in as little as 4 business days. Our flat fee includes your tax case consultation and representing you as Power of Attorney (POA) before the IRS.
Silver $1,500 Full Service If your tax debt is less than $100,000 our flat fee to represent you as Power of Attorney (POA) before the IRS is $500. The fee includes Levy and/or Wage Garnishment release (if financial hardship" exists), potential penalty abatement, Innocent Spouse Relief, Installment Agreement, Offer-in-Compromise (OIC) and/or having you listed as Currently Not Collectible (CNC) by the IRS.
Gold $2,000 Full Service If your tax debt is more than $100,000 our flat fee to represent you as Power of Attorney (POA) before the IRS is $1,500. The fee includes Levy and/or Wage Garnishment release (if "financial hardship" exists), potential Penalty Abatement, Innocent Spouse Relief, Installment Agreement, Offer-in-Compromise (OIC) and/or having you listed as Currently Not Collectible (CNC) by the IRS.
Platinum Fee (to be determined) after we complete a tax debt analysis of your case.If your tax debt is more than $1,000,000 our flat fee to represent you as Power of Attorney (POA) before the IRS will be determined after we complete your tax debt analysis. The fee will include Levy and/or Wage Garnishment removal (if "financial hardship" exists), potential Penalty Abatement, Innocent Spouse Relief, Installment Agreement, Offer-in-Compromise (OIC) and/or having you listed as Currently Not Collectible (CNC) by the IRS.

To obtain a permanent reduction in your tax debt, it's not enough to show the IRS that you can't pay your tax bill. You must also prove you've exhausted all of your financial resources and have little hope of raising money in the future. Offer in Compromise Pre-Qualifier online tool. This online tool can be used to determine if a taxpayer is eligible for an Offer in Compromise (OIC). If the taxpayer is eligible for an OIC they must still complete and submit a Form 656 and a Collection Information Statement. The tool brings the user (the practitioner or the taxpayer) through six steps:

1. Status: This step contains questions to determine the taxpayer’s eligibility for an OIC.

2. Basic info: This step contains questions regarding the taxpayer’s location and their tax debt.

3. Assets: This step contains questions regarding the taxpayer’s assets (FMV and any encumbrances).

4. Income: This step contains questions regarding gross wages, net business and rental income, and other sources of income.

5. Expenses: This step requests information regarding the taxpayer’s necessary living expenses. The tool will consider the local allowable expense criteria for the taxpayer.

6. Proposal: In this step, the tool will suggest a starting point for the offer amount representing the sum of asset equity and present value of future income.

The taxpayer or their authorized representative should use the results from the OIC Pre-Qualifier to complete the required forms in the OIC booklet. If the suggested amount cannot be offered, a lower amount could be justified if the taxpayer has qualifying exceptional circumstances (Section 3 of Form 656).

We will help you with the following:

• Settle your tax debt with the IRS for your "reasonable collection potential" (RCP).
• Handle all negotiations with the IRS for you.
• Protect your paycheck and assets from the IRS.
• Negotiate an affordable monthly payment plan to the IRS.
• Discharge tax liens from your credit and property.
• Negotiate with the IRS even if you have never filed a tax return!

• Solving tax problems. We specialize in past-due returns.

• Attorney referrals to discharge taxes in bankruptcy for certain exceptions.

accountancy • tax services • consulting

Tax Controversy “For those who need it department" (1 of 3)

Tax Controversy “For those who need it department" (2 of 3)

Tax Controversy “For those who need it department" (3 of 3)

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