The IRS sends a CP504 Notice when a taxpayer has failed to pay a balance owed. The CP504 Notice is a Notice of Intent to Levy issued pursuant to Section 6331(d) of the Internal Revenue Code. If a taxpayer fails to make...more
This post focuses on the recent case of Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7, 2022).
The recent Sixth Circuit’s recent opinion in Polselli, et al. v. IRS, Case No. 21-1010 (6th Cir., January 7,...more
A topic that doesn’t get a whole lot of attention from tax professionals is “Currently Not Collectible” (“CNC”) status, which is a status that your account with the IRS may obtain when you cannot currently afford to pay the...more
A topic that we frequently see in the Tax Clinic that I run, one that is often misunderstood, is that of innocent spouse relief. Generally, the purpose of providing innocent spouse relief is to, as one court put it: ...more
The recent case of In re Bowman, Case No. 20-11512, Section A (Bankr. E.D. La., July 12, 2021) addresses an interesting intersection of tax and bankruptcy law. Specifically, it looks at the issue of whether bankruptcy courts...more
The dischargeability of and the ability to collect taxes by the IRS in a consumer bankruptcy case often turn on the issue of whether and when the taxpayer filed the relevant returns, thereby determining when the statute of...more