offer in compromise Archives - Patrick T. Sheehan & Associates, Attorneys at Law, P.C.

Recent Revisions to the Internal Revenue Manual Deny Most Face-to-Face Hearings

As tax practitioners, it is our job to ask the IRS for relief for our clients. Relief can include a request for an installment agreement, a request for penalty abatement, a request for innocent spouse relief or an Offer in…

February 20, 2017

Do I Need To Hire a Tax Attorney?

Are you being audited by the IRS and need to negotiate? Many people survive IRS audits without legal representation. However, you may want to have a tax attorney on speed dial as you go through the audit on your own….

March 24, 2015

IRS Admits That its Collection Due Process Program Has Deficiencies

The Treasury Inspector General for Tax Administration recently conducted an audit of the IRS’ Collection Due Process program. What is Collection Due Process? A taxpayer can request a collection due process (CDP) or equivalent hearing on IRS Form 12153 if…

January 20, 2015

Tax Court Orders IRS to Consider Defunct Business’ Offer in Compromise

A defunct business called Synergy Environmental, Inc., filed an Offer in Compromise with the IRS in August of 2010 offering $600.00 to compromise unpaid federal income tax liabilities. An Offer in Compromise (OIC) allows a taxpayer to “cut a deal”…

September 11, 2014

Offer In Compromise Case Study

An Offer in Compromise is where you “cut a deal” with the IRS and pay less than what you owe. If the IRS believes that you can pay more than what you have offered in an Offer in Compromise…

February 28, 2014

Can My Criminal Tax Conviction Cause the IRS to Reject My Offer in Compromise?

Do you remember the Isley brothers? Ronald Isley was convicted of tax evasion and willful failure to file tax returns in the 1990s and was sentenced to prison and probation. The IRS subsequently attempted to collect Isley’s unpaid tax liability…

December 23, 2013