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1 Contents About This Book How To Use This Book Foreword Acknowledgments About the Author vii ix xi xiii xv Chapter 1 Initial Client Engagement 5 Topical Index Nature of Federal Tax Law Role of the Internal Revenue Service (a) Specific Functions of the Internal Revenue Service Organization of the Internal Revenue Service (a) Examination Process (b) Collection Process (c) The Criminal Investigation Division (CID) (d) Appeals Branch (e) District Counsel Where Do Tax Clients Come From? The Initial Consultation Beginning the Engagement Form Rules of Practice 24 Exhibit 1-1 New IRS Organization Structure 10 Exhibit 1-2 Pre-Payment Appeal Process Examination 12 Exhibit 1-3 Post-Payment Appeal Process Examination/Claims 14 Exhibit 1-4 The Collection Process 15 Exhibit 1-5 The Criminal Process 17 Exhibit 1-6 Initial Client Engagement Checklist 32 Exhibit 1-7 Form 2848, Power of Attorney 33 Exhibit 1-8 Form 8821, Tax Information Authorization 35 Exhibit 1-9 Form 56, Notice Concerning Fiduciary Relationship 37 xvii

2 xviii Dealing with the IRS Exhibit 1-10 Form 4506, Request for Copy or Transcript of Tax Form 39 Exhibit 1-11 CAF Fax Numbers (to Fax Form 2848) 41 Exhibit 1-12 Initial Client Representation Letter 42 Exhibit 1-13 Sample Retainer Agreement 43 Exhibit 1-14 Sample Client Conflict of Interest Letter 45 Exhibit 1-15 Sample Initial Letter to IRS Exhibit 1-16 Sample Memo to File Exhibit 1-17 IRS Publication: Your Rights as a Taxpayer Exhibit 1-18 List of Useful IRS Publications Chapter 2 Examination of Returns 49 Topical Index Audit Basics Pre-Audit Action by Practitioner Conducting the Audit Examination Closing the Audit Examination (a) Statute of Limitations Extension Issues Jeopardy and Termination Assessments Coordinated Examination Program (CEP) Partnership Audit Problems 65 Exhibit 2-1 Examination of Returns Checklist 54 Exhibit 2-2 How To Recognize an Eggshell Audit 55 Exhibit 2-3 Initial Examination Conference Checklist 57 Exhibit 2-4 Ten Negotiating Techniques that Work and Ten that Don t 60 Exhibit 2-5 Closing the Examination Checklist 62 Exhibit 2-6 IRS Audit Notice Corporation 72 Exhibit 2-7 IRS Audit Notice Individual 73 Exhibit 2-8 Thirty-Day Notice 76 Exhibit 2-9 Letter 3164 Notice of Third Party Contact 81 Exhibit 2-10 List of IRS Market Segment Papers 82 Exhibit 2-11 List of Industry Specialization Papers 84 Exhibit 2-12 Form 870 Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment 86 Exhibit 2-13 Form 1902-B Report of Individual Income Tax Exhibit 2-14 Form 4549-E Income Tax Discrepancy Adjustments Exhibit 2-15 Form 4549-CG Income Tax Examination Changes

3 Table of Contents xix Exhibit 2-16 Form 3552(C) Notice of Tax Due on Federal Tax Return (Assessment Document) Exhibit 2-17 Letter Form 921(DO) IRS Proposed Examination Changes for Partner, Shareholder, Beneficiary or Grantor Exhibit 2-18 Form 4089 Notice of Deficiency Waiver 87 Chapter 3 Statute of Limitations 93 Topical Index The Statutes of Limitations in Tax Matters Statute of Limitations on Assessment (a) Extensions of the Statute of Limitations on Assessment Statute of Limitations on Collection Statute of Limitations on Claims for Refund Statute of Limitations on Assessment of Trust Fund Liability: Special Rules for Suspension on the Statute of the Statute of Limitations Mitigation Transferee Liability Limitations Period for Criminal Prosecution 105 Exhibit 3-1 Major Statutes of Limitation 94 Exhibit 3-2 Statute of Limitations Checklist 113 Exhibit 3-3 Suspension of Statute of Limitation 114 Exhibit 3-4 Extend Assessment Statute in Criminal Case 115 Exhibit 3-5 Sample Letter to Client: Trust Fund Penalty Extension 116 Exhibit 3-6 Sample Letter to Client: To Extend Assessment Statute 117 Exhibit 3-7 Sample Letter to Client: No Extension of the Assessment Statute 118 Exhibit 3-8 Form 843 Protective Claim Exhibit 3-9 Letter907(DO) IRS Request for Extension Exhibit 3-10 IRS Publication 1035 Extending the Tax Assessment Period Exhibit 3-11 Form 872 Consent To Extend the Time To Assess Tax 119 Exhibit 3-12 Form 872-A Special Consent To Extend the Time To Assess Tax Exhibit 3-13 Form 872-T Notice of Termination of Special Consent To Extend the Time To Assess Tax Exhibit 3-14 Tax Collection Waiver Exhibit 3-15 Waiver Extending Statutory Period for Assessment of Trust Fund Recovery Penalty

4 xx Dealing with the IRS Exhibit 3-16 Form 843 Claim for Refund and Request for Abatement Exhibit 3-17 Form 1040X Amended U.S. Individual Income Tax Return Chapter 4 Administrative Summons 123 Topical Index Nature of Summons Summons Enforcement Compliance Considerations Defenses to Summons and Right To Quash 128 Exhibit 4-1 Administrative Summons Checklist 134 Exhibit 4-2 Practitioner Objections to Summons 135 Exhibit 4-3 Request for Third Party Contact List 136 Exhibit 4-4 Form 2039: Client Summons Examination Division 137 Exhibit 4-5 Form 6638: Summons for Income Tax Return Collection Branch Exhibit 4-6 Form 2039: Summons Criminal Division Exhibit 4-7 Form 6637: Summons for Collection Information Statement Collection Branch Exhibit 4-8 Summons for Handwriting Exemplar Criminal Division Exhibit 4-9 Form 6540: Handwriting Exemplars Exhibit 4-10 Form 4564: Information Document Request Exhibit 4-11 Letter 3164: IRS Third Party Contact Letter Exhibit 4-12 Form 6882: IDRS/Master File Information Request Exhibit 4-13 Form 6863: Request for Expenses Incident to Summons Exhibit 4-14 Grand Jury Subpoena Exhibit 4-15 Petition To Quash Summons 139 Chapter 5 Appeals Branch 143 Topical Index Nature of Appeals Branch Protest Filing The Appeals Hearing Settlement of Cases in Appeals 151

5 Table of Contents xxi 5.04(a) Appeals Binding Arbitration (b) Collection Due Process Hearings 153 Exhibit 5-1 Advantages/Disadvantages of Appeals Hearing 145 Exhibit 5-2 When Not To File a Protest to Appeals 148 Exhibit 5-3 Appeals Branch Checklist 163 Exhibit 5-4 IRS Thirty-Day Letter 165 Exhibit 5-5 Sample Protest: Income Tax 168 Exhibit 5-6 Sample Protest: 6672 Trust Fund Recovery Penalty 169 Exhibit 5-7 Sample: Appeals Protest Transmittal Letter 172 Exhibit 5-8 Appeals Acknowledgement and Notice of Appeals Hearing 173 Exhibit 5-9 Your Appeal Rights and How To Prepare a Protest If You Don t Agree Exhibit 5-10 Form 870-AD: Offer of Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment Exhibit 5-11 Form 906: Closing Agreement on Final Determination Covering Specific Matters Exhibit 5-12 IRS Letter 913 (RO): Appeals Approval of Settlement Exhibit 5-13 Sample: Letter to IRS To Request Collection Due Process Hearing Exhibit 5-14 Form 12153: Request for Post-Lien/Pre-Levy Collection Due Process Hearing 174 Exhibit 5-15 Sample: Letter to Client Re: Collection Due Process Hearing Exhibit 5-16 Model Arbitration Agreement Chapter 6 Collection Branch 181 Topical Index Nature of Collection Service Center Collection Activity ACS District Office Notices and Forms Filing Tax Liens Tax Levies Taxpayers Advocate Service Offers in Compromise (a) Collateral Agreements and Post Submission Procedures 203

6 xxii Dealing with the IRS 6.10 Bankruptcy Principal Residence Re-Audits Installment Agreements Actions To Enjoin IRS Employment Tax Assessments Innocent Spouse Judicial Review of Collection Action 214 Exhibit 6-1 Getting the Offer in Compromise Accepted Checklist 201 Exhibit 6-2 Applying for Innocent Spouse Relief Checklist 213 Exhibit 6-3 Collection Due Process Hearing Requests 215 Exhibit 6-4 Collection Branch Checklist 230 Exhibit 6-5 The Collection Process 231 Exhibit 6-6 IRS Letter 2843 Notice of Processable Offer in Compromise and Request for Verification 232 Exhibit 6-7 Application for Certificate of Subordination 234 Exhibit 6-8 Application for Certificate of Discharge 237 Exhibit 6-9 IRS Notice CP-504 Urgent Collection Notice 240 Exhibit 6-10 IRS Notice CP-523 Notice of Intent To Terminate an Installment Agreement and To Levy 241 Exhibit 6-11 Form 433-A Collection Information Statement for Individuals 242 Exhibit 6-12 Form 433-B Collection Information Statement for Businesses 246 Exhibit 6-13 Form 433-D Installment Agreement 250 Exhibit 6-14 Form 433-F Collection Information Statement (Short Form) 251 Exhibit 6-15 IRS Letter 3283(DO) IRS Innocent Spouse Determination Letter 254 Exhibit 6-16 IRS Publication 594 The IRS Collection Process Exhibit 6-17 IRS Innocent Spouse Questionnaire Exhibit 6-18 Form 911 Application for Taxpayer Assistance Order (ATAO) Exhibit 6-19 Form 8857 Request for Innocent Spouse Relief Exhibit 6-20 Letter 1153 (DO) Notice of Proposed Trust Fund Recovery Penalty with Protest Instruction Exhibit 6-21 Form 2751 Proposed Assessment of Trust Fund Recovery Penalty (Agreement Form) Exhibit 6-22 Form Request for Collection Due Process Hearing with Instructions

7 Table of Contents xxiii Exhibit 6-23 IRS Letter of Notice of Determination Concerning Collection Actions under Section 6320 and/or 6330 Exhibit 6-24 IRS Publication 1660 Collection Appeal Rights Exhibit 6-25 IRS Publication 1450 Instructions on How To Request a Release of Federal Tax Lien Exhibit 6-26 IRS/ACS Letter 726 Notice of Amount Due on Tax Account Exhibit 6-27 Form 668(W) Notice of Levy on Wages, Salary, and Other Income Exhibit 6-28 Form 668(Y) Notice of Federal Tax Lien Exhibit 6-29 Form 669-A Certificate of Discharge of Property from Federal Tax Lien Exhibit 6-30 Form 669-D Certificate of Subordination of Federal Tax Lien Exhibit 6-31 IRS Publication 783 Instructions on How To Apply for Certificate of Discharge of Property from Federal Tax Lien Exhibit 6-32 IRS Publication 784 How To Prepare Application for Certificate of Subordination of Federal Tax Lien Exhibit 6-33 Form 656 Offer in Compromise Exhibit 6-34 Form 4180 IRS Trust Fund Recovery Penalty Interview Form Exhibit 6-35 Form 668-D Release of Levy/Release of Property from Levy Exhibit 6-36 Form 668-Z Release of Federal Tax Lien Exhibit 6-37 Taxpayer Advocate Service Acknowledgment Letter 256 Exhibit 6-38 Form 668-A(c) Notice of Levy 257 Exhibit 6-39 Form Letter 1058 Notice of Intent to Levy and Right to a Hearing 258 Exhibit 6-40 Form Letter 3172 Notice of Tax Lien Filing and Your Right to a Hearing 261 Chapter 7 Criminal Tax 265 Topical Index Nature of Criminal Investigation Division Specific Procedure Grand Jury Investigations Alternative IRS Investigation Dealing with Special Agents Crimes Investigated by IRS Negotiating the Plea Agreement 277

8 xxiv Dealing with the IRS 7.07 Hearings in District Court for Criminal Violation Plea Hearing Sentencing Hearing Defenses to Criminal Violations SEP 281 Exhibit 7-1 The Criminal Process 267 Exhibit 7-2 Ten Badges of Criminal Tax Fraud 272 Exhibit 7-3 Title 26 Criminal Penalties and Fines 276 Exhibit 7-4 Sentencing Options by Zone 280 Exhibit 7-5 Criminal Tax Checklist 292 Exhibit 7-6 Criminal Tax Appeals Checklist 293 Exhibit 7-7 Rule 11 Plea Hearing Checklist 294 Exhibit 7-8 Sentencing Hearing Checklist 295 Exhibit 7-9 Kovel-CPA Agreement 296 Exhibit 7-10 Sentencing Table 298 Exhibit 7-11 Table Showing Relationship Between Tax Loss and Offense Level 299 Exhibit 7-12 Toughest and Most Lenient States for White Collar Crime 300 Exhibit 7-13 Request for Conference at U.S. Department of Justice 301 Exhibit 7-14 Memo to Client Regarding Rule 11 Proceedings in Federal Tax Crimes 302 Exhibit 7-15 Sentencing Hearing 306 Exhibit 7-16 Defense Memorandum 308 Exhibit 7-17 Request for Conference at U.S. Attorney s Office 312 Exhibit 7-18 Contents of Special Agent s Report 313 Exhibit 7-19 Request for Conference at District Counsel 314 Exhibit 7-20 Referral Report of Potential Criminal Fraud Cases 315 Exhibit 7-21 Application for Permission To Enter Plea of Guilty 317 Exhibit 7-22 District Court Order of Release 324 Exhibit 7-23 District Court Waiver of Indictment 325 Exhibit 7-24 Sample: Assistant U.S. Attorney Letter to Judge Regarding Allocution Questions 326 Exhibit 7-25 Sample: Justice Department Acknowledgment Letter 330 Exhibit 7-26 Explanation of the Pre-Sentence Report Exhibit 7-27 United States District Court s Conditions of Probation and Supervised Release Exhibit 7-28 Sample: Plea Agreement 331 Exhibit 7-29 Sample: U.S. Probation Report; Presentence Investigation Report with Probation Cover Letter Exhibit 7-30 Standing Order of U.S. District Court

9 Table of Contents xxv Chapter 8 Tax Court Practice 339 Topical Index Nature of Tax Court Admission to Practice Petition Filing Trial Practice Small Case Procedure Motion Practice Other Areas of Tax Court Jurisdiction Burden of Proof Claims for Litigation and Administrative Costs Appeals 359 Exhibit 8-1 Advantages/Disadvantages of U.S. Tax Court 341 Exhibit 8-2 Emergency Petition U.S. Tax Court 344 Exhibit 8-3 Format for Briefs Tax Court 349 Exhibit 8-4 Format and Style for Papers Filed in Tax Court 350 Exhibit 8-5 U.S. Tax Court Checklist 366 Exhibit 8-6 Statutory Notice IRS Form Exhibit 8-6A Entry of Appearance 368 Exhibit 8-7 Sample: Petition 369 Exhibit 8-8 Decision Document and IRS Transmittal Letter 371 Exhibit 8-9 Sample: Petitioner s Request for Production of Documents 376 Exhibit 8-10 Tax Court List of Cities 378 Exhibit 8-11 Sample: Designation of Place of Trial Exhibit 8-12 Sample: IRS Answer to Petition Exhibit 8-13 Notice Setting Case for Trial Exhibit 8-14 Standing Pre-Trial Order Exhibit 8-15 Form of Trial Memorandum Exhibit 8-16 Tax Court Subpoena Exhibit 8-17 Tax Court Form of Petition Exhibit 8-18 Tax Court Election of S Case Procedure and Forms Exhibit 8-19 Tax Court Form: Petition for Administrative Costs Exhibit 8-20 Tax Court Form: Application for Order To Take Depositions

10 xxvi Dealing with the IRS Chapter 9 Claims Practice 381 Topical Index Claims Basics Statute of Limitations Full/Divisible Payment Rules IRS Claims Procedure Resort to Courts Choice of Judicial Forum Claim Look-Alikes Tax Payments 391 Exhibit 9-1 Chart: Claims Procedure 382 Exhibit 9-2 Suspension under 6511(h) Disability Checklist 385 Exhibit 9-3 Claim Elements: Informal Claim Doctrine 388 Exhibit 9-4 Claims Checklist 397 Exhibit 9-5 Letter Form 569: Thirty Day Notice 399 Exhibit 9-6 Memorandum in Support of Claim 401 Exhibit 9-7 Protective Claim on Form Exhibit 9-8 Letter Form 906: Notice of Claim Disallowance 405 Exhibit 9-9 Form 2297: Waiver of Statutory Notification of Claim Disallowance 408 Exhibit 9-10 Form 843: Claim for Refund or Abatement 409 Exhibit 9-11 Form 1040X: Amended Individual Tax Return and Instructions for Filing 410 Exhibit 9-12 Form 1120X: Amended Corporate Tax Return 412 Exhibit 9-13 Form 1045: Application for Tentative Refund 414 Exhibit 9-14 Form 1139: Corporation Application for Tentative Refund 418 Exhibit 9-15 Form 870-AD: Appeals Settlement Promising No Claim Filing Exhibit 9-16 Form 1310: Statement of Person Claiming Refund Due for a Deceased Taxpayer Chapter 10 Obtaining Information and Assistance from IRS 423 Topical Index Obtaining Background Information Filing FOIA Requests Obtaining IRS Information On-Line Resolving Taxpayer Problems with the IRS IRS Publications Local IRS Offices 427

11 10.07 Obtaining Private Letter Rulings and Determination Letters Tax and Legal Web Sites 434 Exhibit 10-1 Hierarchy of Tax Authorities 424 Exhibit 10-2 Applying for IRS Rulings 429 Exhibit 10-3 Format for Most Ruling Requests 430 Exhibit 10-4 Obtaining Information and IRS Assistance Checklist 440 Exhibit 10-5 Tax and Legal Web Sites 441 Exhibit 10-6 IRS Transaction Codes 443 Exhibit 10-7 Schedule of Typical User Fees 445 Exhibit 10-8 Table of Contents xxvii Freedom of Information Act (FOIA) Request to District Disclosure Officer 446 Exhibit 10-9 Help with Unresolved Tax Issues 448 Exhibit Taxpayer Advocate Directory 449 Exhibit Form 4506: Request for Copy or Transcript of Tax Form 451 Exhibit The Digital Daily: IRS Newsletter Exhibit Forms and Publications from IRS Web Site Exhibit Tax Information for Businesses from IRS Web Site Exhibit Tax Information for Individuals from IRS Web Site Exhibit Special Report: IRS Problem Solving Day from IRS Web Site Chapter 11 Penalties and Interest 457 Topical Index Accuracy Related Penalty Negligence Penalty Civil Fraud Penalty Innocent Spouse Defense to Penalties Substantial Understatement of Tax Section 6662(b)(2) Substantial Valuation Misstatements Substantial Estate or Gift Tax Valuation Understatement Failure To File Returns Failure To Pay Tax Estimated Tax Penalty Failure To Timely Deposit Trust Fund Recovery Penalty Defense of Reasonable Cause Penalty Appeal Procedure Third Party Penalties Interest 479

12 xxviii Dealing with the IRS Abatement of Interest Miscellaneous 483 Exhibit 11-1 Most Often Assessed Penalties 458 Exhibit 11-2 Obtaining Equitable Innocent Spouse Relief 6015(f) 462 Exhibit 11-3 Trust Fund Recovery Penalty Checklist 471 Exhibit 11-4 Does Reasonable Cause Exist? 474 Exhibit 11-5 Penalty Appeal Procedure Checklist (Post Assessment Prepayment of Penalties) 477 Exhibit 11-6 Schedule of Interest Rates 480 Exhibit 11-7 How To Apply for Zero Interest Netting 482 Exhibit 11-8 Interest Abatement Procedure Checklist 485 Exhibit 11-9 Form 8275 Disclosure Statement 501 Exhibit Letter 1277 IRS Penalty Appeal Determination Letter 503 Exhibit Sample Penalty Appeal Request on Form Exhibit Sample Letter Requesting Penalty Appeal Consideration 508 Exhibit Procedures for Taxpayers To Make Remittances To Stop the Running of Interest on Deficiencies See also the following Exhibits in other chapters: Exhibit 5-6 Sample Protest: 6672 Trust Fund Recovery Penalty 169 Exhibit 6-19 Form 8857 Request for Innocent Spouse Relief Exhibit 6-20 Letter 1153 (DO) Notice of Proposed Trust Fund Recovery Penalty with Protest Instruction Exhibit 6-21 Form 2751 Proposed Assessment of Trust Fund Recovery Penalty (Agreement Form) Exhibit 6-34 Form 4180 IRS Trust Fund Recovery Penalty Interview Form Appendix 509 Index of Subjects 523

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