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- June 5 NYS Tax Litigation Seminar: Completion Certificate June 2, 2025
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- March 13 CPE Seminar: Supplementary Materials March 4, 2025
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Tag Archives: Appeals Office
IRS Collections: Defensive Measures
A taxpayer facing IRS collection should initially determine whether the assessment was timely or whether the 10-year collection period will soon expire. Collections may not proceed if the statute of limitations on assessment was time-barred. Agreeing to extend the statute of limitations on assessment or collection, even if immediate assessment or enforcement action will otherwise is threatened, is not always advantageous. One reason is that interest well above the prime rate will continue to accrue. Continue reading
Posted in IRS
Tagged abatement of interest, Appeals Office, audit, bankruptcy petition, collection due process, federal district court, Freedom of Information Act, innocent spouse relief, installment agreement, IRC § 6015(e), IRC § 6404(e), IRC § 7122. IRC § 6159, IRS collection, IRS levy, judicial review, NFTL, notice of federal tax lien, offer in compromise, refund claim, Reg. § 301.6343-3, statute of limitations, taxpayer assistance order
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IRS Audit Procedures
PDF format: IRS Audit Procedures.wpd The process used to select returns for audit is not a random one. The oft-repeated phrase “audit lottery” is in many ways misleading since certain items, such as claiming a loss on the sale of … Continue reading
Posted in IRS, IRS Audits
Tagged 90 day letter, Appeals Office, audit, claim for refund, deficiency, IRS Audit, notice of deficiency, statute of limitations
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