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Internal Revenue Service Tax Liens Tax Debt

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Freeman Law

Tax Court Says No Collection Due Process Rights in Connection with Treaty Mutual Collection Assistance Request

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In Ryckman v. Commissioner, the U.S. Tax Court tackled an issue of first impression: whether it has jurisdiction over a case challenging the denial by the Internal Revenue Service (“IRS”) of a collection due process (“CDP”)...more

Foodman CPAs & Advisors

Programa De Pasaportes Del IRS Continúa

El IRS había suspendido ciertas actividades de cobro, incluyendo la certificación de pasaportes en respuesta a la pandemia de COVID-19; sin embargo, desde 2021, el IRS retomó su proceso de certificación de pasaportes ante el...more

Foodman CPAs & Advisors

IRS Passport Program Continues

The IRS had suspended certain collection activities including passport certification in response to the COVID-19 pandemic; however, since 2021, the IRS resumed its passport certification process to the U.S. Department of...more

Freeman Law

Tax Court in Brief | Belton v. Comm'r | Seriously Delinquent Tax Debt” and IRS Requirement to Comply with Lien Procedure

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Summary: Petitioners, Willard Belton and Martha-Alexander Belton (Petitioners or Beltons) seeks review pursuant to section 7345(e), challenging the IRS’s certification to the Secretary of State that Petitioners had a...more

Freeman Law

Tax Court in Brief | Adams v. Comm’r | “Seriously Delinquent Tax Debt” and Passport Revocation

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Summary: Petitioner, Blake M. Adams, seeks review pursuant to section 7345(e) of the IRS’s certification to the Secretary of State that Adams has a “seriously delinquent tax debt” related to tax years 2007, 2009, 2010, 2011,...more

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Tax Court in Brief | Mattson v. Comm’r | Passport Revocation Notice for “Seriously Delinquent Tax Debt”; Limitations on Tax Liens

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Tax Litigation: The Week of December 5th, 2022, through December 9th, 2022 - Mattson v. Comm’r, T.C. Memo. 2022-118 | December 6, 2022 |Copeland, J. |Docket No. 16982-18P - Summary: Eric Mattson did not file income tax...more

Freeman Law

TIGTA Finds IRS Is Not Always Following Procedures for Tax Liens

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In 2021, the Internal Revenue Service filed 212,251 Notices of Federal Tax Lien (“NFTLs”). To provide perspective, in 2019 (i.e., pre-COVID-19 pandemic), the IRS filed 543,604 NFTLs. The IRS is working on ramping up its...more

Freeman Law

Tax Court in Brief | Goddard v. Comm'r | Collection Due Process, Penalties for Failure to Register a Tax Shelter

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Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Vorreyer v. Comm’r / Thoma v. Comm’r / Dowson v. Comm’r, T.C. Memo 2022-97| September 21, 2022 | Greaves, Judge | Dkt. Nos. (Consolidated)...more

Freeman Law

Tax Court in Brief | Kotrides v. Commissioner | Collection Due Process, Abuse of Discretion, and Summary Judgment

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Tax Litigation: The Week of June 27th, 2022, through July 1st, 2022 Serna v Commissioner, T.C. Memo. 2022-66 | June 27, 2022 | Urda, J.| Dkt. No. 13202-19L Pedersen v. Commissioner, T.C. Summary Opinion 2022-11 | June 28,...more

Rosenberg Martin Greenberg LLP

IRS Highlights New Policies to Aid Those with Existing Tax Debts

Changes Include Beneficial Payment Plan Options, Less Financial Disclosure for Many with Balances Due, and Ability to Delay Collection Actions - This has been a difficult year for many American taxpayers. In recognition...more

Freeman Law

A Fresh Start for Taxpayers: The Offer in Compromise

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IRS debt can be a life-changing burden.  But for some taxpayers, an offer in compromise may be an avenue to get rid of that tax debt and to receive a fresh start.  When a taxpayer qualifies for an offer in compromise, the IRS...more

Freeman Law

IRS Seizures: The Good, the Bad, and the Ugly

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Along with tax penalties and tax lien filings, the IRS’s ability to seize a taxpayer’s property is one of its most potent weapons to encourage tax compliance.  That is, in part, what makes a recent report from the Treasury...more

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Lincoln Project Founders Have Tax Problems - Two of the people behind the anti-Trump PAC have six-figure debts with the IRS.

The Lincoln Project, an anti-Trump political action committee, has been making headlines for churning out viral videos that question the president’s fitness for office. The PAC, founded by a group of Republican political...more

Rosenberg Martin Greenberg LLP

COLLECTION—When Uncle Sam Crosses the Border: What is in the IRS International Collection Toolbox?

The Internal Revenue Service (“IRS”) faces many challenges when attempting to collect unpaid taxes from taxpayers with foreign assets who reside abroad (“international delinquent taxpayer” or “IDT”). Common obstacles include...more

Rosenberg Martin Greenberg LLP

Collection: Disputing a Notice of Federal Tax Lien Before It Is Filed

Internal Revenue Service (“IRS”) bank account levies and wage garnishments count among the scariest tax collection weapons in the U.S. Treasury arsenal. However, the Notice of Federal Tax Lien (“NFTL”) can, in many cases,...more

Burr & Forman

Appealing A South Carolina State Tax Case: Payment Or Bond?

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Taxpayers who disagree with a proposed tax assessment issued by the South Carolina Department of Revenue (SCDOR or DOR) may or may not be able reach an agreement at the administrative level. When taxpayers and SCDOR cannot...more

Rosenberg Martin Greenberg LLP

Planning to Travel Abroad? Don’t Let the IRS Stop You at the Border. Understanding Recent Guidance Regarding Passport Revocation...

As part of the Fixing America’s Surface Transportation Act (“FAST Act”) of 2015, Congress mandated that the State Department deny any passport application for an individual, or revoke any previously issued passport for an...more

Burr & Forman

New South Carolina Bill Would Centralize Tax Lien Filings – A Good Start But Additional Changes Need to Be Made

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On April 11, 2018, the South Carolina House of Representatives passed House Bill 3684, which will allow the South Carolina Department of Revenue (SCDOR or DOR) to centralize state tax lien filings. State tax lien filings are...more

Burr & Forman

The IRS Has a Lien Against Me: What Do You Do? Tax Lien Release and Discharge (Part 6)

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Where an individual or business owes IRS taxes, Congress has given the IRS a tax lien against all the assets of the taxpayer. The lien covers real estate, homes, furniture, cars, investments, and nearly everything an...more

Foodman CPAs & Advisors

Mayweather vs. McGregor – is it about the FIGHT or is it about the TAXES? Or the Passport?

Much has been published concerning Floyd Mayweather’s Federal Tax Liens in the amount of $22.2 Million and an unpaid 2010 IRS debt of $7.2 Million. The Jasminebrand.com released on 7/21/17 that a $3.3 million federal lien has...more

Burr & Forman

Withdrawal of IRS Tax Liens

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When an individual or business owes federal taxes, a lien arises in favor of the IRS in all property of the delinquent taxpayer. The IRS will often file a notice of this tax lien – a Notice of Federal Tax Lien or “NFTL” – in...more

Foodman CPAs & Advisors

Do You Know About the 4 Scenarios in the IRS Collection Process?

The IRS collection process begins when IRS does not receive full and timely payments from a taxpayer after it issues a collection notice. Based on the information in the taxpayer’s 1040 tax return, if the taxpayer does not...more

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