When the Internal Revenue Service (IRS) files a tax lien it is required by Internal Revenue Code § 6320 to notify taxpayers within 5 business days of the filing of the tax lien. In addition, under Internal Revenue Code § 6320(b) it must provide for a hearing before the Internal…
A district court in Michigan dismissed a complaint challenging an Internal Revenue Service (IRS) tax levy on a couple’s home. The couple owed income taxes of around $300,000 and payroll taxes of another $161,000. They filed a quite title action pursuant to 28 USC 2410, and they also filed an…
The 10th Circuit Court of Appeals has reversed a decision of the United States Tax Court (Tax Court), and held that an Internal Revnue Service Appeals Officer was not impartial within the meaning of Internal Revenue Code (IRC) § 6330. Cox v. Commissioner, No. 06-9004 (2008), reversing, Cox v. Commissioner,…
The Internal Revenue Service (IRS) has published final regulations on releases of federal tax liens and discharges of property. These regulations provide rules for how to go about obtaining the release of a federal tax lien after the tax debt has been paid, or in situations where the statute of…
The Internal Revenue Service (IRS) says that tax audits have increased during the fiscal year ended Sept. 30, 2007. For example the IRS audited 84% more returns of individuals with income of over $1 million dollars than the previous year. This amounted to a tax audit rate of almost 10%.Tax…
Small businesses which get behind on their debts also often fail to pay their payroll taxes resulting in payroll tax problems for the owners. Not paying payroll taxes is a big mistake since the Internal Revenue Service (IRS) can collect the trust fund portion of the payroll tax debt from…
The Internal Revenue Service (IRS) has provided new instructions for persons who wish to file wrongful levy claims against the IRS pursuant to Internal Revenue Code § 6343(b). These instructions are set forth in IRS Publication 4528 (Rev. Nov. 2007). If the IRS were to take your property to pay…
The Internal Revenue Service (IRS) has extended its policy of granting express installment agreements for in business trust fund taxes through at least June 6, 2008. See IRS Memo dated June 6, 2007 Express installment agreements are available to in-business taxpayers who have payroll tax problems of less than $10,000.…
The Internal Revenue Service’s (IRS) Taxpayer Advocate Nina Olsen has released her 2007 Annual Report to Congress. It consists of two large volumes outlining: • The Most Serious Problems Encountered by Taxpayers • Key Legislative Recommendations, and Additional Legislative Recommendations • Most Litigated Issues • Case and Systemic Advocacy. The…