5/3/2015. Dealing with the IRS Collection Division. Eric L. Green. Discussion Topics

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1 Dealing with the IRS Collection Division Presented by Eric L. Green, Esq. Green & Sklarz LLC lawfirm.com Eric L. Green Eric is a partner with Green & Sklarz, LLC in Connecticut. The focus is civil and criminal taxpayer representation Have served as adjunct faculty at the University of Connecticut School of Law Contributing author for Advocating for Low Income Taxpayers: A Clinical Studies Casebook, 3rd Edition. The creator and lecturer for CCH s IRS Representation Certificate Program Current Chair of the Executive Committee of the Tax Section of the Connecticut Bar Association. Discussion Topics The Tax Gap Handling the collection client IRS Collection procedures Collection tools liens and levies The 2012 Fresh Start Initiative and its impact on Collection Opportunities and strategies for resolving the taxpayer s issue 1

2 The Tax Gap Every tax return in the U.S. is audited The IRS uses the Discriminate Function (DIF) system to select tax returns for examination NRP Program launched to update the DIF Tax Gap: $385 billion per year! Collection Stats million taxpayer accounts in the collection division inventory at 12/31/ ,005 liens filed 1,855,095 levies served 74,000 offers in compromise filed, 31,000 accepted (42%) Why Collection Is the Hottest Area Now! Year Accounts in Collection ,478, ,074, ,240, ,232, ,667, ,391, ,809, ,464, ,721, ,410,000 2

3 Assessment of the tax 10 Year Collection Statute Billing Notices Threat to levy and right to a hearing Appeals: CDP, Equivalent and CAP Assessment The IRS will assess the tax when the return is received and processed or it creates a substitute for return (SFR) for the taxpayer Pull transcripts to determine the exact date of assessment 10 Year Statute Pursuant to IRC 6502 the IRS has 10 years to collect a tax debt The 10 year statute begins upon the date of assessment, not the date of filing There are a number of actions that will toll, or suspend, the collection statute 3

4 10 Year Statute Issuance of a notice of deficiency IRC 6503(a) Assets of the taxpayer are in custody of a court IRC 6503(b) The taxpayer is outside the United States for a continuous period of six months or more 6503(c) A wrongful seizure of property or wrongful lien on property 6503(f) 10 Year Statute Taxpayer files bankruptcy IRC 6503(h) The time added for a bankruptcy filing includes the time in bankruptcy plus six months! Filing of a Collection Due Process hearing request Regulation (g) Filing of an Offer in Compromise Regulation (i) Billing Notices The initial billing notice The Notice of Intent to Levy The Final Notice of Intent to Levy and the Taxpayer s Right to a Hearing 4

5 Billing Notice CP 501 Threat to Levy CP 504 Final Notice & Your Right to a Hearing Final Notice Notice Of Intent To Levy And Notice Of Your Right To A Hearing Please Respond Immediately We previously asked you to pay the federal tax shown on the next page, but we haven't received your payment. This letter is your notice of our intent to levy under Internal Revenue Code (IRC) Section 6331 and your right to appeal under IRC Section We may also file a Notice of Federal Tax Lien at any time to protect the government's interest. A lien is a public notice to your creditors that the government has a right to your current assets, including any assets you acquire after we file the lien. If you don't pay the amount you owe, make alternative arrangements to pay, or request an appeals hearing within 30 days from the date of this letter, we may take your property, or rights to property. Property includes real estate, automobiles, business assets, bank accounts, wages, commissions, social security benefits, and other income. We've enclosed Publication 594, which has more information about our collection process; Publication 1660, which explains your appeal rights; and Form 12153, which you can use to request a Collection Due Process hearing with our Appeals Office. To preserve your right to contest Appeals' decision in the U.S. Tax Court, you must complete, sign, and return Form within 30 days from the date of this letter. 5

6 Final Notice and Right to a Hearing Final Notice includes Form Taxpayer has 30 days to request a hearing You MUST file the request If the 30 day window is missed, file for an equivalent hearing Form Appeals: CDP 1998 IRS Restructuring and Reform Act created appeal rights for Collection Cases and gave the United States Tax Court authority to hear collection appeals The IRS is required to give the taxpayer 30 days to request an appeal prior to levying This appeal is referred to as Collection Due Process Appeal, or CDP 6

7 Appeals: CDP If the Form is filed within 30 days requesting a CDP hearing, the case will be forwarded to Appeals All collection action will cease for that tax period, unless the taxpayer continues to pyramid liabilities If the taxpayer continues to incur new tax liabilities, Appeals may grant tax collection division the authority to continue enforced collection activity Appeals: CDP Appeals will contact the taxpayer with a letter confirming they have the case and requesting information Knowing the Appeal was requested, the taxpayer should be preparing the Collection Information Statement (Forms 433) in advance of the hearing Appeals: CDP The hearing is usually by phone, though the representative can request a face to face meeting 7

8 Appeals: Equivalent Hearings If the taxpayer failed to request a CDP hearing, they have up until one year to request an equivalent hearing With an equivalent hearing there is no requirement the IRS cease levy action There is no right to judicial review in the Tax Court Appeals: CAP IRS created a procedural appeal process called the Collection Appeal process, or CAP A CAP appeal can be requested whenever a levy or lien is threatened by the collection division This is a procedural review to make sure the collection division has followed procedure It allows a taxpayer to get their case in front of an appeals officer Levies The seizure of a taxpayer s property Generally issued when a taxpayer has either failed to respond to IRS requests or failed to provide the collection division information 8

9 Levies Two types of levies Regular Continuing Regular Levies A regular levy seizes whatever the taxpayer owns at that moment Examples: bank accounts, receivables, retirement accounts, etc. Banks will hold funds for 21 days before sending them to the IRS Interest that accrues on money held also belongs to the IRS Continuing Levies A continuing levy is a levy that remains in effect until it is released by the IRS Examples include wages and regularly paid commissions IRS will allow the taxpayer a standard deduction and personal exemptions divided by the pay periods (Reg ) Everything above the exempt amount will be taken 9

10 Obtaining a Release of Levy The first step in obtaining a levy release is to provide information requested by the IRS Collection Division, including: Missing tax returns Collection Information Statements Supporting documentation Obtaining a Release of Levy Until the taxpayer is in compliance, there is no deal with the IRS (and no release) Compliance means all returns filed and tax deposits being made Once the taxpayer is in compliance, then a collection alternative can be considered Liens Pursuant to IRC 6321, a lien arises automatically whenever demand for payment is made and the taxpayer fails to pay No other action is required of the IRS IRS may file a Notice of Federal Tax Lien Though the lien arises without any further IRS action, the IRS filed the Notice to inform third party creditors of the IRS lien on the taxpayer s assets to protect its (the IRS s) interest 10

11 Power of the Federal Tax Lien The Lien attaches to all property owned or after acquired Very powerful tool Drye v. U.S. The inheritance U.S. v. Craft Tenancy by the entirety Liens According to the Internal Revenue Manual, an IRS Notice of Federal Tax Lien will be filed whenever a taxpayer owes more than $10,000 Liens IRC 6320 grants the taxpayer the right to a hearing to contest the filing of a notice of federal tax lien Pursuant to IRC 6322 the lien will continue in force until the tax is either paid, compromised, or the 10 year collection statute expires 11

12 Liens Liens are self releasing If the lien becomes unenforceable due to the expiration of the 10 year collection statute, the IRS will not issue a release If the tax is paid or compromised, the IRS will issue a release Lien Discharge and Subordination The IRS will agree to discharge its lien where the taxpayer can demonstrate that upon the sale of the asset 1. The IRS will obtain all of the equity in the asset 2. The IRS will be full paid 3. There is no equity available for the IRS 4. Use IRS Form to request a discharge Lien Discharge and Subordination The IRS will agree to subordinate its lien to another creditor where that creditor will loan money to the taxpayer that will be used either To pay the IRS, or To improve the IRS s ability to collect the tax debt Practitioners should be prepared to argue why and how collection is improved by the IRS agreeing to the subordination 12

13 Resolving a Federal Tax Debt Installments, CNC and Offers Four Options for resolving an outstanding tax debt: Installment Agreements Offers in Compromise Currently Not Collectable Bankruptcy Resolving a Federal Tax Debt Installments, CNC and Offers The decision of which option to use will depend entirely on the taxpayer s unique set of circumstances How much time is left on the statute? Analysis is critical SFR s? CSED Dates? Transcript Analysis 13

14 2012 Fresh Start Initiative Streamlined Agreements Individuals Streamlined Agreements Businesses Lien withdrawal Streamlined Offers in Compromise 2012 Fresh Start Initiative 12 months of future income 3 years for dissipated assets Students loans and misc. expenses Resolving a Federal Tax Debt Installment Agreements There are three types of Installment Agreements Streamlined Regular Partial Pay 14

15 Resolving a Federal Tax Debt Currently Not Collectable (CNC) What is CNC status? How CNC status is determined? When should you seek CNC status? Time to file an Offer? Resolving a Federal Tax Debt Offer in Compromise (OIC) What is an Offer in Compromise, or OIC? When to consider filing an Offer? Types of Offers available? IRS has recently released new Offer and Collection Forms Resolving a Federal Tax Debt Offer in Compromise (OIC) How does the IRS review Offers? Asset Analysis Income Analysis 15

16 Resolving a Federal Tax Debt Offer in Compromise (OIC) Issues with Offers Dissipated Assets Income Averaging Bankruptcy 3 Year Rule 2 Year Rule 240 Day Rule No Fraud No Trust Taxes No SFR Questions 16

17 PRESENTS EFFECTIVELY REPRESENTING TAXPAYERS WHEN WHERE CONFERENCE DATE: NOVEMBER 20th, 2015 FOXWOODS RESORT & CASINO Early Bird Attendee Special 2015 FULL RATE $325 $ EARLY BIRD RATE 2014 ATTENDEE SPECIAL: $199! Must register November 21st - 30th, 2014 ONLY HOTEL ACCOMMODATIONS EARLY BIRD FOXWOODS HOTEL RATE: $129 only while room block lasts! CONFERENCE DATE: NOVEMBER 20th, 2015

18 New England IRS Representation Conference November 20, 2015 Agenda 8:40 9:30 Audits of Cash Businesses (Plenary Session) 9:30 10:20 Breakout Session A-1: Payroll Tax Audits & Worker Classification Breakout Session B-1: How to Read an IRS Transcript 10:20 10:30 Break 10:30 12:00 Payroll Tax Liabilities and Challenging the Trust Fund Recovery Penalty (Plenary Session) 12:00 12:45 Lunch Program (12:15 to 12:45): Dept. of Justice Update Employment Tax Priorities 12:45 1:40: Ethical Issues in Representation (Plenary Session) 1:40 2:30: Breakout Session A-2: Preparing Your Case for Appeals Breakout Session B-2: Tax Liens and Tax Levies 2:30 2:40 Break 2:40 4:30 Breakout Session A-3: Offer-in-Compromise: From Initial Call to Acceptance Letter 2:40 4:30 Breakout Session B-3: The New IRS 8300 BSA Exam: From Routine Compliance to Criminal Prosecution! 4:30 5:45 Payroll Tax Prosecutions: From the Bad to the Criminal (Plenary Session) 5:45 Agostino & Associates IPad Giveaway 5:45 7:00 Cocktail Reception 7:15 - After-Conference Dinner & Party

19 Registration Form 2015 Conference Name: Firm: Billing Address: Billing City/State/Zip: Telephone: PTIN for CPE: Special Pricing Valid through April 30, 2015 $199 In-person attendee at Foxwoods PAYMENT METHOD VISA MASTERCARD AMEX Card Number: Print Name on Card: Signature: Exp. Date: CVV: Billing Zip: TO REGISTER: Complete this form with your payment information and register by: Mail: Green & Sklarz LLC, Attn: NE IRS Representation Conference, 700 State St, Suite 304, New Haven, CT Fax: Attn: NE IRS Representation Conference, Print and scan a copy of the form to Refund Policy: Except in extenuating circumstances, refunds will not be granted after November 1, Cancellations are subject to a $20 service charge to cover processing costs.

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