The Tax Court has found that an IRS settlement officer (SO) abused his discretion in sustaining a proposed levy to collect unpaid trust fund recovery penalties (TFRPs) after the taxpayer's offer in compromise (OIC) had been terminated due to default. The court remanded the case for determination of whether the OIC had been properly terminated.…
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IRS to Start Passport Revocation for Seriously Delinquent Taxpayers
The IRS published on its website, Update on Passport Certifications and Taxpayer Advocate Service, that it is stopping its temporary program under which it wasn't certifying taxpayers for passport revocation etc., if the taxpayer had delinquent tax debt but also had an open Taxpayer Advocate Service (TAS) case.On September 9, 2019 we posted, IRS to Temporarily Stop…
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Jointly Owned Property By Siblings Subject To IRS Lien
A federal district court has held in Dase, (DC AL 9/23/19), that property subject to an IRS lien was jointly owned by a tax debtor and his sister. Therefore, the IRS’s lien only encumbered the tax debtor’s interest in the property. In 2004, the taxpayer, Scott Dase, entered into a lease-to-own agreement with his parents Walter and…
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IRS Grants Relief and Safe Harbors for Certain Foreign Stock Ownership!
On October 2, 2019 we posted, IRS Grants Relief for Certain Foreign Stock Ownership! where we discussed new regulations from the Internal Revenue Service provide relief to some U.S. taxpayers who own stock in certain foreign corporations. Rev. Proc. 2019-40 and the proposed regulations limit the inquiries required by U.S. taxpayers to determine whether certain foreign businesses are controlled foreign…
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