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RTRP’s are not authorized to represent taxpayers (see IRS IRM Section 5.8.3.18 “…Individuals who are not authorized to practice before the IRS with respect to a collection matter (such as unenrolled return preparers and registered tax return preparers) may accompany taxpayers to meetings with a completed Form 8821…”) however they can accompany taxpayers to meetings [...]
This depends on who is liable for the unpaid tax included in the offer. Assuming that only one spouse is liable such as in a liability that stems from unpaid taxes prior to marriage or the assessment Trust Fund Recover Penalty (“TFRP”), you would combine income if the taxpayers’ income pays for joint expenses and [...]
The most commonly used formula is 12 times monthly disposable income plus quick sale value of assets. For alternatives, overviews and detailed case study refer to our textbook The Ultimate Guide to Tax Resolution.
Yes. No offer will be accepted if the taxpayer files for or is already in bankruptcy proceedings when their offer has been submitted and is under consideration.
Yes. See: If you submitted an appeal of an Offer In Compromise and it gets rejected where do you go?
Assuming your client’s offer in compromise was rejected by the IRS Offer Specialist assigned to their case, you have a few options as follows moving up the chain in seniority. You can appeal to the Specialist’s direct supervisor, the Group Manager. If you are unsuccessful you can request to argue your position to the Group [...]
Yes and no. Yes the taxpayer can obtain the funds from family or friends. When we submit an offer, we usually state that the money being used to pay the offer was borrowed from family friends, and not gifted. This information is entered in the section on the form where the IRS asks for the [...]
Since we carefully analyze the applicant’s numbers before submitting an offer, our acceptance rate is higher than 90%. Keep in mind that vetting offers very closely yields this high percentage. In addition we are aggressive in the appeals process when it becomes necessary. Luckily this is not very often. We find that most offers are [...]
Yes. The statute tolls (freezes) for the time the offer is under consideration plus 180 days plus 30 days for the rejection appeal period (IRM 5.1.19.3 (01-01-2006)).
Assuming the stockbroker is conducting his business on a cash basis, the IRS will most likely not look into the value of his or her book of business directly, however; they may consider the value with respect to the ability to earn going forward. The argument against considering the “value” of the book might be [...]
The 20% deposit you include with an offer in compromise submission is not refundable. The deposit will be applied to prior year taxes, penalties and interest if the offer is rejected.
An offer in compromise may seem like the “obvious” choice but this is not always the case. Assuming the client qualifies for an offer there are still other questions that must be answered before deciding to proceed. One is “Does the prize justify the price?” Offers are expensive to prepare when compared to the costs [...]
Assuming the corporation is still in business, two separate offers in compromise must be submitted. Keep in mind that it is difficult to have an in-business offer accepted. If the corporation is closed and all necessary paperwork has been filed, a business offer is most often not necessary and only one 656 will need to [...]
Yes. See: If you submitted an appeal of an Offer In Compromise and it gets rejected where do you go?
Assuming your client’s offer in compromise was rejected by the IRS Offer Specialist assigned to their case, you have a few options as follows moving up the chain in seniority. You can appeal to the Specialist’s direct supervisor, the Group Manager. If you are unsuccessful you can request to argue your position to the Group [...]
The majority of offers range from $7,000 to $10,000
