Most of the time, this column is devoted
|
|
- Thomas Long
- 8 years ago
- Views:
Transcription
1 Tax Practice By William D. Elliott Potpourri of Tax Practice Issues TAXES THE TAX MAGAZINE William D. Elliott practices tax law in Dallas, Texas, with particular experience in tax procedure and controversy and IRS conflict resolution. Bill is author of the leading treatise, FEDERAL TAX COL- LECTION, LIENS & LEVIES and a Fellow of the American College of Tax Counsel. CCH Draft Most of the time, this column is devoted to one topic. This column will discuss a variety of tax practice issues that are percolating near the surface. Some of the topics derive from comments or questions from practitioners, which are welcome. Nominee Transferee Alter Ego Liens IRS collection actions against nominees and alter egos of the delinquent taxpayer is receiving heightened awareness. 1 A nominee lien is used when the IRS believes when property has been transferred or acquired in the name of a third party with the taxpayer s funds. The IRS can file a nominee lien without court order, but only with IRS legal approval. Asset seizure can follow from a nominee lien. 2 The remedy from a nominee lien is not especially attractive because it requires a lawsuit in U.S. District Court under 28 USC An alter ego is used by the IRS when they believe one entity is alter ego of another, such as when the taxpayer fails to observe corporate formalities. 3 Innocent Spouse Developments The IRS announced on July 25, 2011, 4 that it will no longer enforce Reg (b)(1), which limited to two years after the date of the IRS s first collection activity the period in which it would consider requests for equitable relief under Code Sec. 6015(f). Now, the IRS will consider requests for innocent spouse 11
2 Tax Practice relief under Code Sec. 6015(f) at any point in time as long as the period of limitation on collection of taxes provided by Code Sec remains open for the tax years at issue. In Notice , the IRS provides a proposed revenue procedure that will supersede Rev. Proc , 5 which provides guidance regarding Code Sec. 6015(f) relief from joint and several liability. 6 The factors used in making Code Sec. 6015(f) innocent spouse relief determinations will be revised to ensure that requests for innocent spouse relief are granted under [Code Sec.] 6015(f) when the facts and circumstances warrant. Usually, the innocent spouse is the wife. Abused wives often involve the issue of whether the husband exerted financial control over the couple s affairs. When a wife has been abused by her husband, she may not have been able to challenge the treatment of any items on the joint return, question the payment of the taxes reported as due on the joint return or challenge the husband s assurance regarding the payment of the taxes. Furthermore, a wife s lack of financial control may have a similar impact on her ability to satisfy joint tax liabilities via IRS collection actions. Thus, the IRS guidelines indicate that abuse or lack of financial control may mitigate other factors that might otherwise weigh against granting Code Sec. 6015(f) equitable relief. The proposed revenue procedure also provides for certain streamlined case determinations; new guidance on the potential impact of economic hardship; and the weight to be accorded to certain factual circumstances in determining equitable relief. 7 Liberalizing Some IRS Collection Standards and Thresholds In recent times, the IRS has liberalized standards for various collection actions, or increased payment thresholds, which are particularly useful for installment agreements and offers in compromise. Installment Payment Changes and Lien Withdrawals The IRS announced changes to its criteria for tax lien filings and when an installment agreement will be The challenge facing practitioners who try to cope with this complex array of rules, systems and faceless IRS persons is huge. Perhaps the unspoken story is how the tax collection system works at all CCH. CCH All Draft Rights Reserved. used without having to supply the IRS with a financial statement has been raised to $50,000 from $25,000. Additionally, the maximum term for streamlined installment agreements has been raised to 72 months from 60 months. 8 The IRS has filed 41 percent fewer notices of tax liens during the March 2012 period from a year earlier, and 61 percent fewer liens filed by Automated Collection System. 9 On the other hand, as of March 2012, those businesses receiving installment agreements has declined as compared with earlier periods. 10 The new procedures do not seem to have increased the use of installments agreements, in fact. Penalty Relief for Unemployed from Failure-to-Pay Penalties New penalty relief has been announced by the IRS for those unemployed for failure-to-pay penalties when balance due amount do not exceed $50,000. The IRS plans to grant a six-month grace period to (1) wage earners who have been unemployed at least 30 consecutive days during 2011, or in 2012 up to the April 17 deadline for filing tax returns; and (2) self-employed individuals who experienced a 25-percent or greater reduction in business income in The penalty relief is subject to income limits, the IRS added. A taxpayer s income must not exceed $200,000 if he or she files married filing jointly or $100,000 as single or head of household. 11 Offers in Compromise Changes The IRS liberalized somewhat offers in compromise in instances when tax liabilities are less than $50,000 and gross income is $100,000 or less and there are no employment tax liabilities. Essentially, the IRS is limiting background research, relying to a greater degree on internal research, telephone communications with taxpayer, and liberalizing expenses and future income calculations. 12 Also, in IR the IRS indicated other adjustments to offers in compromise: Consider future income for only one year, if the offer in compromise is paid in five or few months. Consider future income for only two years, if the offer in compromise is paid in six to twenty-four months (reduced from five years).
3 Consider more taxpayer-favorable computation of future income potential and living expenses (allowing loan guarantee payments of a high school education and allowing some state and local taxes). 14 Surprisingly, the rate of acceptance of offers in compromise has increased to 38 percent. The actual number of offers accepted doubled during the March 2012 period from earlier similar periods. 15 Available statistics indicate increased inventories of OIC cases, together with processing delays. 16 Reality Check in Collection Due Process Cases Recent Tax Court statistics on winners and losers in Collection Process cases remind practitioners that most of the time, the IRS prevails in the Tax Court on CDP cases. The Taxpayer Advocate reported statistics on Collection Due Process cases in the Tax Court for the first part of 2011, which indicate that the IRS wins these most of the time. From June 1, 2010, to May 31, 2011, the Tax Court issued 89 cases involving CDP hearings. Of these, taxpayers prevailed in three, and in part in three other cases. Of these six cases in which taxpayer prevailed in whole or in part, taxpayers were pro se in three cases. 17 These 89 cases are a reduction of 32 percent from the 131 decisions published by the Tax Court for the previous 12-month period. The IRS enjoys a success rate in the Tax Court in CDP cases of 90 percent + in all years since 2003 (89 percent in 2010). Centralization and Automation of IRS Collection Activities The IRS agency is underfunded and in need of greater manpower. The IRS business strategy is to centralize functions and automate as much as possible. The National Taxpayer Advocate has been writing about these issues in each of her annual reports, and particularly her 2011 report. Consider the following telling statistics: In 2011, the Automated Substitute for Return program processed 896 percent more returns than in Automated adjustments are occurring more than actual exams. In 2010, out of 15 million IRS contacts with taxpayers, only 10 percent were real examinations. Of these 10 percent real examinations, some 78 percent (of the 10 percent) were by correspondence in an automated setting, not actual examinations of returns. The IRS filed 1,042,230 notices of federal tax lien in 2011 against 713,524 taxpayers (5.2 percent less than 2010). The Advocate has concluded that increased lien filings did not lead to higher tax collections, and in fact, probably lessen tax collections. In 2011, 3.7 million collection cases remain unresolved after the notice phase and moved into ACS. Sixty percent of ACS cases have been in the system for six months or more. The dollar value of cases in the collection queue has doubled over the last six years to $56.2 billion. In 2010, the IRS Excess Collections File held $4.7 billion. This is the file containing funds the IRS has not applied or credited to a taxpayer s account, nor refunded. The Treasury Inspector General for Tax Administration (TIGTA) estimates more than one-half of the transfers to the Excess Collection File were due to IRS errors. When Confronting an Unreasonable IRS Position: IRS Levy on a Lawyer s Client Trust Funds The phone call referenced from a leading tax attorney in Dallas introduced the subject of what are useful strategies for the practitioner when confronting an unreasonable IRS position in a collection matter. In this instance, the IRS was levying on a lawyer s client trust funds, when the delinquent taxpayer was the lawyer and not the lawyer s client. The IRS collection action is unusual and even unreasonable because under the laws of most, if not all, states, clearly provides that client trust funds held by a lawyer are client property, not the lawyer s property. Therefore, the IRS collection action is unreasonable because the property sought to be levied belongs to the client, not the lawyer, and therefore the IRS is not entitled to levy it. This point is so very obvious. Texas law is perfectly clear in identifying monies in a lawyer s trust funds as client property. This is not a nominee or alter ego situation. The lawyer cannot touch the client trust funds without client approval without risk of jeopardizing the lawyer s law degree and perhaps even invoke criminal sanction. The only justification for the IRS levying on the client trust funds is that the lawyer s property, the taxpayer s TAXES THE TAX MAGAZINE 13 CCH Draft
4 Tax Practice property if you will, includes the client trust funds, which is not the case. Therefore, the IRS is wrong in asserting the levy and unreasonably wrong. What is the practitioner to do? The practitioner could consider several strategies, which are outlined in the following paragraphs. Contact IRS Revenue Officer s Supervisor or Manager Errant IRS collection actions can often be stopped by the practitioner contacting the supervisor or manager of the Revenue Office who then would presumably see the light and stop the wrongful levy. Unfortunately, in modern times, IRS supervisors or managers seem less likely to be willing to overrule errant Revenue Officers. Perhaps the Revenue Office consulted with his or her manager or supervisor in advance of the levy and afterwards is unlikely to reverse the agreed upon action. Nevertheless, the effort required by the practitioner to speak to the manager or supervisors is not great and might prove successful. In the actual example, the supervisor or manager would not overrule the Revenue Officer. Release of Levy Under Code Sec There are administrative and judicial actions available when a levy is wrongful. Code Sec provides that the IRS official for a geographical area has authority to release a levy on all or part of the property or rights to property levied upon where (1) it is determined that release of the levy will facilitate collection, or (2) the levy was wrongful. 18 A levy is wrongful, and subject to Code Sec. 6343(b) (except that no interest will be paid), if the IRS determines that (1) the levy was premature or otherwise not in accordance with the IRS s administrative procedures. 19 One problem with a levy release is timing. The author does not know of any statistics, but informal information would suggest timing measure in months, not days. Contact IRS Counsel or Taxpayer Advocate. The practitioner could attempt to contact IRS counsel in the belief or hope that an IRS lawyer will quickly recognize that the taxpayer-lawyer does not have any property right in the client trust funds and thus persuade the IRS Revenue Office to stop trying to collect from someone other than the taxpayer. For many practitioners, they do not have acquaintance with IRS counsel and are uncomfortable with a blind call. Also, IRS counsel might not want to become involved until the case appears in their inventory. Another strategy is to request assistance of the Taxpayer s Advocate Office. The Advocate s office has the power to intervene and order the IRS Revenue Office to stop its collection action. Collection Appeal Program A useful approach is to invoke the Collection Appeal Program (CAP). 20 The Collection Appeals Program allows a taxpayer faced with a notice of lien, levy, seizure or denial or termination of an installment agreement to challenge any procedural errors in the collection activity. A byproduct of the strategy of using the Collection Appeals Program is to obtain a short-term respite from the collection function. The statutory authority for the Collection Appeals Program is Code Sec. 7123(a), which statutorily binds the IRS to follow its internal administrative procedures with respect to Collection Appeals Program. 21 Under the Collection Appeals Program, tight time periods are set forth for the various steps by taxpayers and IRS officials. If the taxpayer first receives a notice from the IRS, then the taxpayer is instructed to contact the Collection manager by telephone. The time period for Collection managers to return telephone requests for review to taxpayers is twenty-four hours. Collection Due Process Hearing The practitioner could seek a Collection Due Process Hearing under Code Sec for Tax Court review of the levy. There are various requirements, among which is timing. CDP hearings take months, not days. 22 Suit for Wrongful Levy A suit for wrongful levy is authorized by Code Sec. 7426, which is a permitted judicial action when there has been a wrongful levy. 23 There is a set of requirements for this suit with which there must be compliance. The problem with a suit for wrongful levy is that it takes too long. A U.S. District Court lawsuit will take months, not days. Injunction The availability of an injunction is a possible strategy in the example presented. Normally, one would not consider an injunction against the IRS because the Anti-Injunction Act, Code Sec. 7421, prohibits suits against the IRS for injunction. In the instant example, an injunction is probably obtainable since the IRS CCH. CCH All Draft Rights Reserved.
5 is engaged in a procedurally irregular collection process, 24 or the IRS will not prevail under any circumstances. 25 Damage Claim for Wrongful Collection Action A taxpayer may sue the United States if an IRS collection employee recklessly or intentionally, or by reason of negligence violates the Code. 26 Fundamentals to Remember First, the bank holding the client trust funds has no choice when confronted with this levy but follow standard procedure and give notice under the 21-day rule and then turn over the funds. There is no useful purpose served in the practitioner attempting to persuade the bank to not comply with the levy. A party upon whom a levy describing particular property has been served is not required to determine the true owner of the property, nor whether the property is subject to levy. The bank is not liable for complying with the levy. 27 Levies are provisional remedies. The levy is designed to give the IRS control or custody of the levied funds, not determine title to the funds. Ownership disputes are to be resolved in post-levy administrative or judicial remedies. 28 Any recitation of current topics facing the practitioner must include the realization that tax practitioners confront the system every day. The challenge facing practitioners who try to cope with this complex array of rules, systems and faceless IRS persons is huge. Perhaps the unspoken story is how the tax collection system works at all. ENDNOTES 1 See recent analysis of nominee, transferee, alter ego liens: R. McKenzie, Nominee Liens & Alter Ego Liens, American Bar Association Section of Taxation, May 2012 Meeting, May 11, 2012, 2012 ABATAX-CLE ; W. Elliott, Tax Practice, Coping With Nominee Liens, TAXES, May 2011, at 13; W. Elliott, Tax Practice, The Troublesome Transferee Liability, TAXES, July 2012, at IRM (Mar. 27, 2012); CCA (Aug. 30, 2002). 3 W. ELLIOTT, FEDERAL TAX COLLECTIONS, LIENS & LEVIES (WGL 2012), Notice , IRB , 135 (July 25, 2011). 5 Rev. Proc , CB Notice , IRB , 309 (Jan.6, 2012). 7 IRS CCN CC (Jan. 05, 2012); IR (Jan. 5, 2012); Notice , IRB , 309 (Jan. 6, 2012); Rev. Proc , IRB , 455 (Feb. 15, 2012). See National Taxpayer Advocate, Fiscal Year 2013 Objectives Report to Congress (June 30, 2012), at SBSE (Mar. 27, 2012); IR (Mar. 7, 2012); IR , IRS Announces New Effort to Help Struggling Taxpayers Get a Fresh Start; Major Changes Made to Lien Process (Feb. 24, 2011). 9 Collection Activity Report NO , Liens Report (Apr. 2012). See National Taxpayer Advocate, Fiscal Year 2013 Objectives Report to Congress (June 30, 2012), at Collection Activity Report NO , Installment Agreement Cumulative Report (Apr. 2012). See National Taxpayer Advocate, Fiscal Year 2013 Objectives Report to Congress (June 30, 2012), at IR (Mar. 12, 2012). 12 SBSE (Feb. 27, 2012), set to expire one year later, Feb. 27, IR (May 21, 2012). 14 SBSE (May 21, 2012), also to last only one year until May 21, Collection Activity Report NO , Monthly Report of Offer in Compromise Activity (Apr. 2012). See W. Elliott, FEDERAL TAX COLLEC- TIONS, LIENS & LEVIES (WGL 2012), at TIGTA, Ref No , Increasing Requests for Offers in Compromise Have Created Inventory Backlogs and Delayed Responses to Taxpayers, (Mar. 30, 2012). See National Taxpayer Advocate, Fiscal Year 2013 Objectives Report to Congress (June 30, 2012), at National Taxpayer Advocate, Annual Report to Congress Code Sec. 6343(a), (b). 19 Code Sec. 6343(d). 20 The Collection Appeals Program was created in Announcement 96-5, IRB , 1. See W. Elliott, FEDERAL TAX COLLECTIONS, LIENS & LEVIES (WGL 2012), at IRM 8.7, Technical and Procedural Guidelines, 1.1.9, Collection Appeals Program (Jan. 1, 1999). 22 W. ELLIOTT, FEDERAL TAX COLLECTIONS, LIENS & LEVIES (WGL 2012), at Code Sec. 7426(a). 24 Enochs v. Williams Packing & Navigation Co., SCt, 62-2 USTC 9545, 370 US 1 (1962). 25 Id., at 7; S. Shapiro, SCt, 76-1 USTC 9266, 424 US 614 (1976). 26 Code Sec. 7433(a). 27 Code Sec. 6332; Reg (c). 28 National Bank of Commerce, SCt, 85-2 USTC 9482, 472 US 713, 730. TAXES THE TAX MAGAZINE 15 CCH Draft
Advocating for Levy Release and Return of Levy Proceeds. Rev. 5/27/2014
Advocating for Levy Release and Return of Levy Proceeds Rev. 5/27/2014 Vinatieri v. Comm r 133 T.C. 392 (2009) Proposed levy on bank account for 2002 liability Collection Due Process hearing established
More informationCivil Actions to Enforce Federal Tax Liens or to Subject Property to Payment of Tax Under IRC 7403
MLI #9 Civil Actions to Enforce Federal Tax Liens or to Subject Property to Payment of Tax Under IRC 7403 SUMMARY Internal Revenue Code (IRC) 7403 authorizes the United States to file a civil action in
More informationAutomated Collection System (ACS)
Automated Collection System (ACS) 245 Designed by IRS to streamline it s unpaid account collection, however: Tax practitioners struggle with many of it s organization concepts Inability to contact previous
More informationScheduled for a Public Hearing. Before the SENATE COMMITTEE ON FINANCE. on April 5, 2001. Prepared by the Staff. of the JOINT COMMITTEE ON TAXATION
OVERVIEW OF PRESENT LAW RELATING TO THE INNOCENT SPOUSE, OFFERS-IN-COMPROMISE, INSTALLMENT AGREEMENT, AND TAXPAYER ADVOCATE PROVISIONS OF THE INTERNAL REVENUE CODE Scheduled for a Public Hearing Before
More informationThe IRS has attempted to balance enforcement
Practice By Charles P. Rettig A Fresh Start for Struggling Taxpayers Charles P. Rettig is a Principal with Hochman, Salkin, Rettig, Toscher & Perez, P.C. in Beverly Hills, California. Mr. Rettig is Chair
More informationThe Examination Process. The IRS Mission
The IRS Mission Provide America s taxpayers top quality service by helping them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all. The Examination
More informationThe Nuts and Bolts of Handling a Pro Bono Tax Controversy Case. Presented by The ABA Section of Taxation
The Nuts and Bolts of Handling a Pro Bono Tax Controversy Case Presented by The ABA Section of Taxation Panelists Caroline Ciraolo - Rosenberg, Martin, Greenberg, LLP, Baltimore, Maryland Catherine Engell
More informationFORM 941/944 W2 / W3 1099 / 1096
FORM 941/944 W2 / W3 1099 / 1096 DIRECTLY FROM: THE IRS PUBLICATION 15 CIRCULAR E The penalties do not apply if any failure to make a proper and timely deposit was due to reasonable cause and not to willful
More informationThe Government Accountability Office (GAO)
April May 2010 Collection Employment Tax Collection Case By Patti Logan Patti Logan, EA, specializes in taxpayer representation before the Collection Division. As a former Revenue Officer, she brings a
More informationPURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.
PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2004-30 UNITED STATES TAX COURT JOHN WILLIAM HOLLIS, Petitioner,
More informationTREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION Increasing Requests for Offers in Compromise Have Created Inventory Backlogs and Delayed Responses to Taxpayers March 30, 2012 Reference Number: 2012-30-033
More informationTaxpayer Bill of Rights Adopted June 10, 2014
1. The Right to Be Informed Taxpayers have the right to know what they need to do to comply with the tax laws. They are entitled to clear explanations of the laws and IRS procedures in all tax forms, instructions,
More informationThe IRS Private Debt Collection Program A Comparison of Private Sector and IRS Collections While Working Private Collection Agency Inventory
The IRS Private Debt Program A Comparison of Private Sector and IRS s While Working Private Agency Inventory SECTION SIX Penalties and Private Debt The IRS Private Debt Program A Comparison of Private
More informationTAXPAYER RIGHTS ACT OF 2015: SECTION-BY-SECTION SUMMARY
TAXPAYER RIGHTS ACT OF 2015: SECTION-BY-SECTION SUMMARY TAXPAYER RIGHTS Section 101. Statement of Taxpayer Rights. Section 101 requires the Secretary of the Treasury to publish a Taxpayer Bill of Rights
More informationCan You Get the IRS to Pay Part of Your Representation Fees? *
Tax Practice & Procedure/February March 2005 Can You Get the IRS to Pay Part of Your Representation Fees? * By David M. Fogel David Fogel explains the rules of Code Sec. 7430 and encourages practitioners
More informationMost Litigated Issues
Most Serious Appendices MSP #7 HARDSHIP LEVIES: Four Years After the Tax Court s Holding in Vinatieri V. Commissioner, the IRS Continues to Levy on Taxpayers it Acknowledges are in Economic Hardship and
More informationPart III Administrative, Procedural, and Miscellaneous. 26 CFR 601.203: Offers in Compromise (Also Part I, 7122; 301.7122-1) Rev.
Part III Administrative, Procedural, and Miscellaneous 26 CFR 601.203: Offers in Compromise (Also Part I, 7122; 301.7122-1) Rev. Proc 2003-71 SECTION 1. PURPOSE The purpose of this revenue procedure is
More informationIRS Form 668-W Part 1
IRS Form 668-W Part 1 REPLY THIS ISN'T A BILL FOR TAXES YOU OWE. THIS IS A NOTICE OF LEVY TO COLLECT MONEY OWED BY THE TAXPAYER NAMED ABOVE. The Internal Revenue Code provides that there is a lien for
More informationWhen the IRS attempts to collect a tax
January 2014 By William D. Elliott Tax Collection Against Independent Contractors William D. Elliott practices tax law in Dallas, Texas, with particular expertise in tax procedure and controversy and IRS
More informationBRIEF SUMMARY: The bill amended the Revenue Act to create an "offer-in-compromise" program within the Department of Treasury.
Legislative Analysis OFFER-IN-COMPROMISE TAXPAYER AGREEMENTS House Bill 4003 as enacted Public Act 240 of 2014 Sponsor: Rep. John Walsh House Committee: Tax Policy Senate Committee: Finance Mary Ann Cleary,
More informationAGOSTINO & ASSOCIATES, P.C. IRS Collections. Presented by : Frank Agostino
AGOSTINO & ASSOCIATES, P.C. IRS Collections Presented by : Frank Agostino DISCLAIMER: The following materials and accompanying Access MCLE, LLC audio program are for instructional purposes only. Nothing
More informationv. DECISION AND ORDER Plaintiff Kenneth Holmes, proceeding pro se, alleges that his employer s
Case 1:14-cv-00357-RJA Document 12 Filed 07/08/14 Page 1 of 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK KENNETH L. HOLMES, Plaintiff, 14-CV-357-A v. DECISION AND ORDER KATHY BROOKS, in
More informationSpecial Report: IRS Tax Lien
Special Report: IRS Tax Lien TAX PLANNING AND IRS DEFENSE C a l l T o d a y! 540-438- 5344 What an IRS Tax Lien is and How it Works What is Inside? Why the IRS Files a Notice of Federal Tax Lien IRS Tax
More informationLegal Aid Society of Orange County Low Income Taxpayer Clinic
Legal Aid Society of Orange County Low Income Taxpayer Clinic Presented by: Renato L. Izquieta, Esq. Legal Aid Society of Orange County Presented by: Richard Silva, Paralegal Legal Aid Society of Orange
More informationTREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION Fiscal Year 2015 Statutory Review of Restrictions on Directly Contacting Taxpayers July 7, 2015 Reference Number: 2015-30-061 This report has cleared the
More informationOffer in Compromise. Worksheets to calculate an acceptable offer amount using Form 433-A and/or 433-B and Publication 1854*
Department of Treasury Internal Revenue Service Form 656 (Rev. 1-97) Catalog Number 16728N Form 656 Offer in Compromise What you should know before submitting an offer in compromise Worksheets to calculate
More informationTAX PROCEDURE (DN 893) ASSIGNMENT 28 - - - SETTLEMENT AGREEMENTS WITH THE IRS (DRAFT DATE - DECEMBER 8,, 2014) Table Of Contents
TAX PROCEDURE (DN 893) ASSIGNMENT 28 - - - SETTLEMENT AGREEMENTS WITH THE IRS (DRAFT DATE - DECEMBER 8,, 2014) Table Of Contents Table Of Contents... -1- Assignment 28 - - - Settlement Agreements With
More informationWRITTEN TESTIMONY OF BRYAN C. SKARLATOS, ESQ. given it powers to collect money and property that far exceed those of any ordinary creditor.
WRITTEN TESTIMONY OF BRYAN C. SKARLATOS, ESQ. The Internal Revenue Service (the Service ) is a Super Creditor because Congress has given it powers to collect money and property that far exceed those of
More informationThe IRS Collection Process Publication 594
The IRS Collection Process Publication 594 Page 1 The IRS Collection Process Publication 594 This publication provides a general description of the IRS collection process. The collection process is a series
More informationBRIEF SUMMARY: The bill would amend the Revenue Act to create an "offer-in-compromise" program with Department of Treasury.
Legislative Analysis OFFER-IN-COMPROMISE TAXPAYER AGREEMENTS House Bill 4003 (reported from committee without amendment) Sponsor: Rep. John Walsh Committee: Tax Policy Mary Ann Cleary, Director Phone:
More informationThis notice expands the period within which individuals may request equitable
Part III - Administrative, Procedural, and Miscellaneous Equitable Relief Under Section 6015(f) Notice 2011-70 PURPOSE This notice expands the period within which individuals may request equitable relief
More informationChapter 13 Bankruptcy
Chapter 13 Bankruptcy Individual Debt Adjustment The chapter of the Bankruptcy Code providing for adjustment of debts of an individual with regular income. (Chapter 13 allows a debtor to keep property
More informationChapter 13 - Bankruptcy Basics. Background. Advantages of Chapter 13
Chapter 13 - Bankruptcy Basics This chapter of the Bankruptcy Code provides for adjustment of debts of an individual with regular income. Chapter 13 allows a debtor to keep property and pay debts over
More informationMost Litigated Issues
Most Serious Appendices MSP #11 COLLECTION STRATEGY: The Automated Collection System s Case Selection and Processes Result in Low Collection Yields and Poor Case Resolution, Thereby Harming Taxpayers RESPONSIBLE
More informationStatement of Colleen M. Kelley National President National Treasury Employees Union H.R. 4735
Statement of Colleen M. Kelley National President National Treasury Employees Union On H.R. 4735 Presented to House Committee on Oversight and Government Reform Subcommittee on Federal Workforce, Postal
More informationDESCRIPTION OF THE CHAIRMAN S MODIFICATION TO H.R. 1562, THE KATRINA HOUSING TAX RELIEF ACT OF 2007
DESCRIPTION OF THE CHAIRMAN S MODIFICATION TO H.R. 1562, THE KATRINA HOUSING TAX RELIEF ACT OF 2007 Scheduled for Markup by the HOUSE COMMITTEE ON WAYS AND MEANS on March 21, 2007 Prepared by the Staff
More informationTAX PROCEDURE (DN 893) ASSIGNMENT 29 - - - INSTALLMENT AGREEMENTS WITH THE IRS (DRAFT DATE - DECEMBER 8, 2014) Table Of Contents
TAX PROCEDURE (DN 893) ASSIGNMENT 29 - - - INSTALLMENT AGREEMENTS WITH THE IRS (DRAFT DATE - DECEMBER 8, 2014) Table Of Contents Table Of Contents... -1- Assignment 29 - - - Installment Agreements With
More informationFederal Tax Issues in Bankruptcy A View From Your Friends at the IRS and DOJ
Federal Tax Issues in Bankruptcy A View From Your Friends at the IRS and DOJ Richard Charles Grosenick Office of Chief Counsel IRS Special Assistant United States Attorney 211 W. Wisconsin Ave. Suite 807
More informationTITLE XXIII CLAIMS FOR LITIGATION AND ADMINISTRATIVE COSTS
RULE 231 (7/6/12) 153 TITLE XXIII CLAIMS FOR LITIGATION AND ADMINISTRATIVE COSTS RULE 230. GENERAL (a) Applicability: The Rules of this Title XXIII set forth the special provisions which apply to claims
More informationCOLLECTION POLICY CHANGES & FRESH START INITIATIVES (FY 2011) Capitol of Texas Enrolled Agents CPE November 8, 2011
COLLECTION POLICY CHANGES & FRESH START INITIATIVES (FY 2011) Capitol of Texas Enrolled Agents CPE November 8, 2011 LEVIES & ECONOMIC HARDSHIP Vinatieri v. Commissioner (2009) If the taxpayer establishes
More informationThe individual or husband and wife must be engaged in a farming operation or a commercial fishing operation.
Chapter 12 Background: Chapter 12 is designed for "family farmers" or "family fishermen" with "regular annual income." It enables financially distressed family farmers and fishermen to propose and carry
More informationFollowing the conviction of a defendant for a
Practice By Charles P. Rettig Criminal Tax Restitution Orders and the Civil Liability Charles P. Rettig is a Principal with Hochman, Salkin, Rettig, Toscher & Perez, P.C. in Beverly Hills, California.
More informationEric L. Green, Esq. The IRS Restructuring and Reform Act of 1998 created Collection Due Process ( CDP )
Tax Compliance, Economic Hardship and the IRS Levy: The Recent Tax Court Decision in Vinatieri v. Commissioner Changes the Impact of Tax Compliance on Hardship Cases Eric L. Green, Esq. The IRS Restructuring
More informationTREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION The Fresh Start Initiatives Have Benefited Many Taxpayers, but Additional Monitoring and Evaluation Is Needed December 30, 2014 Reference Number: 2015-30-005
More informationDEALING WITH THE IRS
DEALING WITH THE IRS 2 3 DEALING WITH THE IRS More individuals deal with the IRS than any other federal government agency. The IRS processes more than 100 million individual income tax returns every year.
More informationSelected Issues from the 2013 National Taxpayer Advocate Report *
Selected Issues from the 2013 National Taxpayer Advocate Report * By William D. Elliott William D. Elliott selects a few topics to examine from The National Taxpayer Advocate 2013 Annual Report to Congress.
More informationINTERNAL REVENUE SERVICE
INTERNAL REVENUE SERVICE WRITTEN TESTIMONY OF LINDA STIFF ACTING COMMISSIONER OF INTERNAL REVENUE BEFORE THE SENATE COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS PERMANENT SUBCOMMITTEE ON INVESTIGATIONS
More information[How To Get out of a Bind]
[How To Get out of a Bind] By Howard S. Levy, JD When the IRS strikes with a levy, bad things can happen. Even though money is needed to put food on the table, erty. Although our clients are often most
More informationAvoid the IRS Maze When Representing Clients: Know How the IRS Works and What to Do When Representing Clients
Avoid the IRS Maze When Representing Clients: Know How the IRS Works and What to Do When Representing Clients This course looks at the organization of the IRS, including the IRS divisions involved with
More informationPITFALLS IN REPRESENTING A CLIENT BEFORE THE IRS. WSBA Brown Bag CLE September 25, 2008. Robert M. Kane, Jr. LeSourd & Patten, P.S.
PITFALLS IN REPRESENTING A CLIENT BEFORE THE IRS WSBA Brown Bag CLE September 25, 2008 Robert M. Kane, Jr. LeSourd & Patten, P.S. (206) 624-1040 There are numerous pitfalls for the practitioner who represents
More informationGuide to IRS Collections
CPE/CE 1 Credit Hour Guide to IRS Collections Tax Payment Options and Solutions 2012 Tax Year Interactive Self-Study CPE/CE Course Course Overview Program Content: Publication Date: September 2012. Expiration
More informationCHAPTER 234 HOUSE BILL 2131 AN ACT AMENDING SECTIONS 12-348, 41-1007 AND 42-2064, ARIZONA REVISED STATUTES; RELATING TO TAX ADJUDICATIONS.
Senate Engrossed House Bill State of Arizona House of Representatives Fifty-second Legislature First Regular Session 0 CHAPTER HOUSE BILL AN ACT AMENDING SECTIONS -, -00 AND -0, ARIZONA REVISED STATUTES;
More informationFEDERAL TAX LIENS FOR REAL ESTATE PROFESSIONALS:
FEDERAL TAX LIENS FOR REAL ESTATE PROFESSIONALS: THE INSIDE SCOOP ON WHAT THEY ARE AND HOW YOU (AND YOUR CLIENTS) CAN DEAL WITH THEM ERIC L. GREEN, ESQ. Copyright 2011 About the Author The focus of Attorney
More informationChapter 213. Enforcement of Texas Unemployment Compensation Act... 2 Subchapter A. General Enforcement Provisions... 2 Sec. 213.001.
Chapter 213. Enforcement of Texas Unemployment Compensation Act... 2 Subchapter A. General Enforcement Provisions... 2 Sec. 213.001. Representation in Court... 2 Sec. 213.002. Prosecution of Criminal Actions...
More informationTAX PROCEDURE (DN 893) ASSIGNMENT 39 - - - COURTS - UNITED STATES DISTRICT OF COLUMBIA CIRCUIT COURT (DRAFT DATE - MARCH 26, 2014) Table Of Contents
TAX PROCEDURE (DN 893) ASSIGNMENT 39 - - - COURTS - UNITED STATES DISTRICT OF COLUMBIA CIRCUIT COURT (DRAFT DATE - MARCH 26, 2014) Table Of Contents Table Of Contents... -1- Assignment 39 - - - Courts
More information2015 TAX COURT JUDICIAL CONFERENCE
2015 TAX COURT JUDICIAL CONFERENCE CONFLICTS AND CHAOS: THE IMPORTANCE OF TIMELY RECOGNIZING AND MANAGING CONFLICTS OF INTEREST AND RELATED PROBLEMS IN TAX LITIGATION Discussion Hypotheticals May 22, 2015
More informationBlispay Card agreement
Blispay Card agreement 1. Definitions 2. How Blispay Card works 3. Making payments 4. Fees and interest 5. When things go wrong 6. Arbitration Provision 7. Legal 8. Communications and information sharing
More informationIRC 6330 and Tax Collection Rights
THE STATE BAR OF CALIFORNIA TAXATION SECTION TAX PROCEDURE AND LITIGATION COMMITTEE LACK OF COLLECTION DUE PROCESS RIGHTS FOR CO-OWNERS OF PROPERTY: A CALIFORNIA COMMUNITY PROPERTY PERSPECTIVE This paper
More informationDEPARTMENT STORES NATIONAL BANK CREDIT CARD DISCLOSURES. This APR will vary with the market based on the Prime Rate.
(DSNB180TC122315) (PL068) DEPARTMENT STORES NATIONAL BANK CREDIT CARD DISCLOSURES Interest Rates and Interest Charges Annual Percentage Rate 24.75% * (APR) for Purchases Store Accounts This APR will vary
More informationCase 3:13-cv-01238-JPG-PMF Document 18 Filed 10/21/14 Page 1 of 6 Page ID #78 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS
Case 3:13-cv-01238-JPG-PMF Document 18 Filed 10/21/14 Page 1 of 6 Page ID #78 RICHARD M. O DONNELL, Plaintiff, UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS v. Case No. 13-cv-1238-JPG-PMF
More informationDET710. A Guide to Tax Resolution: Solving IRS Problems - 12 Hours
DET710 A Guide to Tax Resolution: Solving IRS Problems - 12 Hours Course Objectives and Outline Chapter 1 - IRS Overview and Taxpayer Rights 1. List the mission of the IRS. 2. State the role of Taxpayer
More informationDESCRIPTION OF THE CHAIRMAN S MARK OF A PROPOSAL TO CREATE A MILITARY SPOUSE JOB CONTINUITY CREDIT
DESCRIPTION OF THE CHAIRMAN S MARK OF A PROPOSAL TO CREATE A MILITARY SPOUSE JOB CONTINUITY CREDIT Scheduled for Markup by the SENATE COMMITTEE ON FINANCE on February 11, 2015 Prepared by the Staff of
More information5/3/2015. Dealing with the IRS Collection Division. Eric L. Green. Discussion Topics
Dealing with the IRS Collection Division Presented by Eric L. Green, Esq. Green & Sklarz LLC www.gs lawfirm.com Eric L. Green Eric is a partner with Green & Sklarz, LLC in Connecticut. The focus is civil
More informationOffer in Compromise. Attach Application Fee and Payment (check or money order) here. IRS Received Date. (Rev. May 2012) Section 3
Form 656 (Rev. May 2012) Department of the Treasury Internal Revenue Service Offer in Compromise Attach Application Fee and Payment (check or money order) here. Section 1 Your Contact Information Your
More informationUnderstanding IRS Collection Procedures
I. Collection Begins with Assessment Understanding IRS Collection Procedures Unit One- Assessment Learning Objectives After completing this Unit you should have an understanding of: A. Overview What an
More informationREG-152166-05 Taxpayer Assistance Orders
DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 301 REG-152166-05 Taxpayer Assistance Orders RIN 1545-BF33 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Withdrawal of notice
More informationWharton Aldhizer & Weaver PLC. Tax Controversy Newsletter A Monthly Update on Tax Procedure and IRS Enforcement Actions in the Mid-Atlantic
Wharton Aldhizer & Weaver PLC Tax Controversy Newsletter A Monthly Update on Tax Procedure and IRS Enforcement Actions in the Mid-Atlantic Issue Matt Von Schuch Tax Attorney and CPA Legislative Updates
More informationThis revenue procedure provides guidance regarding a new, voluntary Annual
ANNUAL FILING SEASON PROGRAM Rev. Proc. 2014-42 SECTION 1. PURPOSE This revenue procedure provides guidance regarding a new, voluntary Annual Filing Season Program designed to encourage tax return preparers
More informationCACalifornia Taxpayers Bill of Rights
CACalifornia Taxpayers Bill of Rights Inside 01 Taxpayers Bill of Rights legislation enacted 1988 02 Taxpayers Bill of Rights legislation enacted 1997 Information for Taxpayers» 03 California Taxpayers
More informationTAX LIENS AND LEVIES
Howard L. Richshafer, J.D. C.P.A. Wood & Lamping, LLP 600 Vine Street, Suite 2500 Cincinnati, OH 45202 (513) 852-6027 May 2014 I. BACKGROUND AND INTRODUCTION. TAX LIENS AND LEVIES A. IRS filed 700,000
More informationDESCRIPTION OF THE TAXPAYER PROTECTION ACT OF 2007
DESCRIPTION OF THE TAXPAYER PROTECTION ACT OF 2007 Scheduled for Markup By the HOUSE COMMITTEE ON WAYS AND MEANS on March 28, 2007 Prepared by the Staff of the JOINT COMMITTEE ON TAXATION March 26, 2007
More informationYour Appeal Rights Before the IRS
Your Appeal Rights Before the IRS Prepared by the Tax Department of GIBSON & PERKINS, PC Suite 204 100 W. Sixth Street, Media, PA 19063 610-565-1708 www.gibperk.com I. Examination of Returns A. In General
More informationMEMORANDUM ON TRUSTEE S MOTIONS TO DISMISS
MEMORANDUM ON TRUSTEE S MOTIONS TO DISMISS In certain circumstances, the Trustee will file a motion to dismiss a Chapter 13 bankruptcy proceeding. The purpose of this Memorandum is to discuss the most
More informationThe I.R.S. Amnesty Program & The New Streamlined Filing Compliance Procedures
TOPICS IN THE SEMINAR INCLUDE: The I.R.S. Amnesty Program & The New Streamlined Filing Compliance Procedures By Richard S. Lehman, Esq. TAX ATTORNEY www.lehmantaxlaw.com SEMINAR INTRODUCTION by Richard
More informationLow Income Taxpayer Clinics (LITCs) 2012 Interim and Year-End Report General Information
Interim and Year-End Report General Information OMB Number -6 Name of clinic University of Washington School oflaw Federal Tax Clinic Reporting Period D Interim Report - January through June!RI Year-End
More informationTREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION Revenue Officers Took Appropriate Levy Actions but Face Challenges and Delays Bringing Taxpayers Into Compliance November 21, 2011 Reference Number: 2012-30-007
More informationChapter 25. Tax Administration and Practice. Eugene Willis, William H. Hoffman, Jr., David M. Maloney and William A. Raabe
Chapter 25 Tax Administration and Practice Eugene Willis, William H. Hoffman, Jr., David M. Maloney and William A. Raabe Copyright 2004 South-Western/Thomson Learning Tax Administration (slide 1 of 3)
More informationThe Taxpayer Advocate Service: Recent Developments in Taxpayer Advocacy
Dallas CPA Society s Continuing Education Day Conference May 26, 2011 Dallas, TX The Taxpayer Advocate Service: Recent Developments in Taxpayer Advocacy Joel N. Crouch, J.D. 901 Main Street, Suite 3700
More informationSAMPLE BANKRUPTCY DISCHARGE FORM Page 1 of 2
One Division Avenue Room 200 Grand Rapids, MI 49503-3132 Phone : (616) 456-2693 http://www.miwb.uscourts.gov/ WHAT IS CHAPTER 7 BANKRUPTCY? Chapter 7 bankruptcy, sometimes call a straight bankruptcy is
More informationThe IRS Collection Process Keep this publication for future reference Publication 594
IRS Mission: Provide America s taxpayers top quality service by helping them understand and meet their tax responsibilities and by applying the tax law with integrity and fairness to all. What You Should
More informationUsually, a low-income taxpayer receives several notices (sometimes as many as
PART III. COLLECTION CASES...1 OVERVIEW:...1 A. REASONABLE COLLECTION POTENTIAL... 1 B. CURRENTLY NOT COLLECTIBLE... 3 C. PARTIAL INSTALLMENT AGREEMENTS.... 3 D. INSTALLMENT AGREEMENTS... 4 E. PREPARING
More informationOffer in Compromise (Doubt as to Liability)
Form 656-L Offer in Compromise (Doubt as to Liability) CONTENTS What you need to know...2 Important information...2 Form 656-L...5 IRS contact information If you have questions about qualifying for an
More informationThe Federal Circuit Affirms a Court of Federal Claims Decision Dismissing Foreign Tax Credit Refund Claims as Untimely
Tax Controversy Services IRS Insights In this issue: The Federal Circuit Affirms a Court of Federal Claims Decision Dismissing Foreign Tax Credit Refund Claims as Untimely... 1 The Court of Federal Claims
More informationGAO TAX COMPLIANCE. Businesses Owe Billions in Federal Payroll Taxes. Report to Congressional Committees
GAO United States Government Accountability Office Report to Congressional Committees July 2008 TAX COMPLIANCE Businesses Owe Billions in Federal Payroll Taxes On December 19, 2008, the PDF file was revised
More informationUNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT BARBARA JANE KNUDSEN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 13-72077 Tax Court No. 18048-09
More informationGAO TAX ADMINISTRATION. IRS Use of Enforcement Authorities to Collect Delinquent Taxes. Testimony Before the Committee on Finance, U.S.
GAO United States General Accounting Office Testimony Before the Committee on Finance, U.S. Senate For Release on Delivery Expected at 9:00 a.m. EDT Tuesday, September 23, 1997 TAX ADMINISTRATION IRS Use
More informationCLIENT INFORMATION: GUIDELINES ON ADMINISTRATION & BILLING
CLIENT INFORMATION: GUIDELINES ON ADMINISTRATION & BILLING As updated from time-to-time for billing rates and responsible attorney and, following actual notice to the client. This agreement forms the basis
More informationInnocent Spouse Relief (And Separation of Liability And Equitable Relief)
Publication 89 Innocent Spouse Relief (And Separation of Liability And Equitable Relief) Pub 89 (2/15) Note: A Publication is an informational document that addresses a particular topic of interest to
More informationStatement before the. Committee on Ways and Means. Subcommittee on Select Revenue Measures. United States House of Representatives
Statement before the Committee on Ways and Means Subcommittee on Select Revenue Measures United States House of Representatives Hearing on Small Business and Tax Reform Alvin S. Brown, Esq., Tax Attorney
More informationHow To Defend Yourself In A Tax Court
Escape Conviction when Prosecuted for a Federal Tax Crime Court, DOJ, IRS no jurisdiction without specific Section of Title 26 quoted Why, in a "Federal District Court" when charged with a "tax crime"
More informationFiscal Year 2011 Report to the Congress on the Use of Section 7623
Fiscal Year 2011 Report to the Congress on the Use of Section 7623 Table of Contents I. Executive Summary... 1 II. Program History... 2 A. Prior Law and Policy... 2 B. 2006 Amendments... 3 C. Implementing
More informationCONSIDERATIONS AND STRATEGIES WHEN THE TAXPAYER IS ALREADY IN TROUBLE
CONSIDERATIONS AND STRATEGIES WHEN THE TAXPAYER IS ALREADY IN TROUBLE By Leslie Shields Attorney at Law The Shields Law Firm, P.L.L.C. 402 S. Northshore Drive Knoxville, Tennessee 37919 Phone (865) 546-2400
More informationTAX PROCEDURE (DN 893) ASSIGNMENT 46 - - - ESTOPPEL (DRAFT DATE - APRIL 3, 2014) Table Of Contents. Table Of Contents... -1-
TAX PROCEDURE (DN 893) ASSIGNMENT 46 - - - ESTOPPEL (DRAFT DATE - APRIL 3, 2014) Table Of Contents Table Of Contents... -1- Assignment 46 - - - Estoppel... -2- Examine the following nine provisions of
More informationUpdates to Affordable Care Act: Law, Regulatory Explanation and Analysis, 2014
Updates to Affordable Care Act: Law, Regulatory Explanation and Analysis, 2014 Chapter 2. Individuals 205. Individual Health Insurance Mandate In December 2013, the Administration announced that individuals
More informationPRESENT LAW AND BACKGROUND RELATING TO WORKER CLASSIFICATION FOR FEDERAL TAX PURPOSES
PRESENT LAW AND BACKGROUND RELATING TO WORKER CLASSIFICATION FOR FEDERAL TAX PURPOSES Scheduled for a Public Hearing before the SUBCOMMITTEE ON SELECT REVENUE MEASURES and the SUBCOMMITTEE ON INCOME SECURITY
More informationTREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION Fiscal Year 2015 Statutory Review of Compliance With Legal Guidelines When Issuing Levies June 18, 2015 Reference Number: 2015-30-058 This report has cleared
More informationSpousal Access Trust Makes Use of Enlarged Gift Tax Exemption
Spousal Access Trust Makes Use of Enlarged Gift Tax Exemption Properly drafted mutual trusts let couples take advantage of the $5.12 million gift tax exemption before it expires, without relinquishing
More informationDESCRIPTION OF THE CHAIRMAN S MARK OF A PROPOSAL TO CLARIFY SPECIAL RULE FOR CERTAIN GOVERNMENTAL PLANS
DESCRIPTION OF THE CHAIRMAN S MARK OF A PROPOSAL TO CLARIFY SPECIAL RULE FOR CERTAIN GOVERNMENTAL PLANS Scheduled for Markup by the SENATE COMMITTEE ON FINANCE on February 11, 2015 Prepared by the Staff
More informationThe CNMI Division of Revenue and Tax s Collection Process Keep this publication for future reference
DIVISION OF REVENUE AND TAXATION COMMONWEALTH OF THE NORTHERN MARIANA ISLANDS Post Office Box 5234 CHRB Saipan, MP 96950 Tel. (670) 664-1000 What You Should Know About The CNMI Division of Revenue and
More informationUNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA
Case 4:12-cv-00296-CVE-FHM Document 24 Filed in USDC ND/OK on 10/22/12 Page 1 of 8 UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OKLAHOMA MARK ANDRES GREEN, Plaintiff, v. Case No. 12-CV-0296-CVE-FHM
More information