Collection procedures, including but not limited to:

  • Advising after notice and demand for payment after assessment;
  • Fighting tax liens (general (unfiled) and filed) upon assessment and failure to pay;
  • Arguing ten (10) year statute of limitation on collections;
  • Properly applying offsets of refunds to the correct tax year;
  • Fighting tax levies on the taxpayer and third parties;
  • Arguing constitutional protections on IRS levies;
  • Arguing no beneficial ownership in property seized by the IRS;
  • Advising on priority of tax liens;
  • Drafting and negotiating many installment agreements under 433-A, 433-B, 433-F, 433-D and 9465;
  • Assisting clients with the streamlined installment agreements;
  • Assisting taxpayers into the position of “currently not collectible or collection suspense”;
  • Assisting taxpayers with offers in compromise under 656, including offers as to doubt as to collectability and doubt as to liability;
  • Assisting bankruptcy attorneys with determining the different types of taxes that can and cannot be discharged;
  • Arguing taxpayer is not a responsible person and subject to the trust fund recovery tax;
  • Requesting protection from IRS collection efforts under collection appeals program and collection due process;
  • Innocent spouse relief including joint liability relief under 6015(b); divorced or legally separated relief under 6015(c); and equitable relief under 6015(f);
  • Separate liability relief for community property items;
  • Nominee and transferee liability;
  • Liability for trust fund taxes;
  • Trust fund penalty under 6672; and
  • Beneficiary and donee liability under 6324.