The Internal Revenue Service Collection Process, by statue and structure, targets full payment requiring a complete review of a Taxpayer’s assets and liabilities. Taxpayers unable to pay the full amount have a limited number of options defined by the IRS, not Congress, and one defined by the Bankruptcy Code.
The course will examine the statutes, the IRS collection structure, the options offered by the IRS, the basic approach to a collection problem (“when is a taxpayer unable to pay in full within the statute of limitations”) and how to evaluate all of the options and decide which one best suits your client’s needs.
The Internal Revenue Code contains provisions called “Collection Due Process Hearings” to address the IRS’s ultimate collection tools- filing a Notice of Federal Tax Lien and a levy on the tax payer’s money accounts. We will review the administrative hearing, the review by the United States Tax and how that impacts your client’s choice of options and the timing.
This course will define how a tax debt can be discharged in bankruptcy and how bankruptcy compares to an Offer-In-Compromise as more efficient and more effective.
WM. Robert Pope, JR, Esq.
April 10, 2019