News & Analysis as of

Tax Liability Tax Debt Internal Revenue Service

Foodman CPAs & Advisors

IRS Use of AI Can Close Tax GAP

On 10/12/23, the IRS announced new tax gap projections for tax years 2020 and 2021 showing the projected gross tax gap increased to $688 billion in tax year 2021, a rise of more than $192 billion from the prior estimates for...more

Freeman Law

Certificates of Discharge from IRS Liens

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I previously posted about the process for requesting the subordination of an IRS lien – that post can be found here. However, as noted in that post, subordination is primarily useful in cases where a taxpayer intends to keep...more

Rivkin Radler LLP

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

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Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

Foodman CPAs & Advisors

Revocación O Denegación De Pasaporte Continúa

El 1/1/24, el IRS actualizó su página de revocación o denegación de pasaporte en casos de ciertos impuestos no pagados. La Sección 7345 del Código de Rentas Internas requiere que el Departamento del Tesoro de los EE. UU....more

Foodman CPAs & Advisors

Passport Revocation Or Denial Continues

On 1/1/24, the IRS updated its Passport Revocation or Denial Page in cases of certain unpaid taxes. Section 7345 of the Internal Revenue Code requires the U.S. Department of the Treasury to notify the U.S. Department of...more

Fox Rothschild LLP

IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

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The IRS expects to send out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. As part of the new collection initiative, approximately...more

Foodman CPAs & Advisors

Avisos De Cobros Del IRS Se Reiniciarán En 2024

Avisos de Cobros del IRS se reiniciarán en 2024 así como un nuevo alivio de multas para aproximadamente 4.7 millones de personas, empresas y organizaciones exentas de impuestos a las que no se les envió un recordatorio...more

Foodman CPAs & Advisors

IRS Collection Notices To Re-Start In 2024

On 12/19/23, the IRS announced the restart of IRS collection notices as well as a new penalty relief for approximately 4.7 million individuals, businesses and tax-exempt organizations that were not sent an automated IRS...more

Foodman CPAs & Advisors

The Tax Gap Increased To $688 Billion In Tax Year 2021

On 10/12/23 announced new tax gap projections for tax years 2020 and 2021 showing the projected gross tax gap increased to $688 billion in tax year 2021, a rise of more than $192 billion from the prior estimates for tax years...more

Lerch, Early & Brewer

IRS Levy Allowed on Classic Italian Cello to Satisfy Outstanding Estate Tax Liabilities

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United States v. Firestone - In United States v. Firestone, the United States (Government or U.S.) sought to enforce a judgment against Defendant Omar Firestone (Omar) for outstanding tax liabilities related to the Estate of...more

Rivkin Radler LLP

Self-Employment Tax and the Limited Partner – Substance Over Form, or Something Else?

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Last week, the IRS announced “the start of a sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promoters abusing the...more

Kohrman Jackson & Krantz LLP

Move Over TikTok, the Tax Man May Be Snooping on You, Too

In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...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

Freeman Law

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

Foodman CPAs & Advisors

Is Your U.S. Passport In Jeopardy?

A Taxpayer’s U.S. Passport could be in jeopardy if the U.S. Taxpayer has seriously delinquent tax debt. The law authorizes the IRS to certify seriously delinquent tax debt to the U.S. State Department for the State...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

Freeman Law

Tax Court in Brief | Ezekwo v. Commissioner | Passport Revocation for Seriously Delinquent Tax Debt

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Tax Litigation:  The Week of May 30th, 2022, through June 3rd, 2022 Ezekwo v Commissioner, T.C. Memo. 2022-54 | May 31, 2022 | Lauber, J.| Dkt. No. 15454-21P...more

Venable LLP

Should Your Lawyer Be a Grammar Nerd?

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Sometimes, yes. At least that’s one takeaway from the argument in a recent U.S. Supreme Court case, Boechler, P.C. v. Commissioner of Internal Revenue. ...more

Gray Reed

Negotiating with the IRS Collection Division

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Once the IRS makes an assessment against a taxpayer, the taxpayer will receive several notices before the IRS takes enforced collection action....more

Freeman Law

Currently Not Collectible Status

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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

Freeman Law

Tough Luck, Taxpayer!—IRS Continues to Levy on Social Security Benefits

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Many taxpayers (if not all) would agree with the sentiment expressed on a wall plaque that recently caught my eye: “Dear IRS: I would like to cancel my subscription. Please remove my name from your mailing list.” That feeling...more

Freeman Law

[Webinar] Freeman Law Legal and Tax Update - March 30th, 1:00 pm CT

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Join us as we discuss important developments during these unique times, and bring you up to speed on current initiatives. Business are still facing unprecedented challenges, and we are here to provide insights. During...more

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