Tax Controversy

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  • IRS Offer in Compromise

    IRS Offer in Compromise: A Treatise for Attorneys, CPAs, Accountants & Tax Preparers

    $199

    This treatise offers tax professionals a scholarly treatise on the IRS program that relieves taxpayers from crushing IRS back-taxes. This is a must-have resource book for any tax professional offering Offer in Compromise services. Citing specific authorities, this book offers a deep dive into the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures that comprise the IRS’ Offer in Compromise program. The 12-page Table of Contents, 27-page Table of Authorities, and 18-page Index aids a tax professional’s scholarly understanding.

  • innocent spouse

    IRS Innocent Spouse Tax Relief: A Treatise for Attorneys, CPAs & Tax Preparers

    $189

    This book offers tax professionals a scholarly treatise on the IRS program that relieves a requesting spouse (or former spouse) from joint and several tax liability. Innocent spouse relief is offered on equitable grounds or when the tax is attributable to a non-requesting spouse’s bad behavior – including fraud, income concealment, income misstatement, and unwarranted expense deductions or tax credits. This book offers a deep dive into the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures that comprise the IRS’ Innocent Spouse Tax Relief program. This is a resource book for tax professionals.Congress authorized relief to the “innocent” spouse who would otherwise be inequitably harmed by the non-requesting spouse. The three types of relief from joint and several tax liability are analyzed with relevant citations to the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures. A separate discussion is presented for Innocent Spouse Relief, Separation of Liability Relief, and Equitable Relief, including a line-by-line analysis of IRS Form 8857, Request for Innocent Spouse Relief. The book also explores premature and untimely relief claims, appellate review of rejected claims, and refund claims after relief is granted. IRS Innocent Spouse Tax Relief: A Treatise for Attorneys, CPAs & Tax Preparers also explores the IRS collection process with a discussion of IRS levies, tax liens, installment agreements, the offer in compromise program, and currently not collectible status. Finally, powers of attorney and third-party authorizations are examined, including a line-by-line analysis of IRS Form 2848, Power of Attorney and IRS Form 8821, Tax Information Authorization.  An 8-page Table of Contents, a 19-page Table of Authorities, and a 9-page Index aids a tax professional’s scholarly understanding.

    IRS Offer in Compromise, Installment Agreements & Innocent Spouse Relief: A Treatise for Tax Professionals

    $250

    This treatise offers tax professionals a 664-page scholarly treatise on the IRS programs that relieve taxpayers from crushing IRS back-taxes. This is a must-have resource book for any tax professional offering back-tax relief services. Citing specific authorities, this book offers a deep dive into the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures that comprise the IRS’ back-tax relief programs. The 22-page Table of Contents, 48-page Table of Authorities, and 28-page Index aids tax professionals’ scholarly understanding.

    DIY Guide to IRS Offer in Compromise & The Fresh Start Initiative

    $96

    This book offers taxpayers an all-encompassing presentation of the IRS program that relieves taxpayers from crushing IRS back-taxes. This is a must-have book for any taxpayer challenging the IRS without the help of a tax lawyer. Written by a tax attorney, this book makes the process as easy as possible, including a line-by-line analysis of IRS Form 656, Offer in Compromise and Form 433-A (OIC), Collection Information Statement for Wage Earners and Self-Employed Individuals. For a fuller understanding, this book also offers a deep dive into the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures that comprise the IRS’ Offer in Compromise program, which is also known as The Fresh Start Initiative.

    IRS Installment Agreements: A Treatise for Attorneys, CPAs, Accountants & Tax Preparers

    $189

    Installment agreements are offered to taxpayers who want to avoid IRS collections and repay back-taxes over time. This book offers a deep dive into the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures that comprise the IRS’ Installment Agreement program. This is a resource book for tax professionals. Congress authorized relief from the IRS collections apparatus, including protection from bank levies, wage garnishments, lawsuits, and federal tax liens. “Routine” installment agreements are explored first, followed by the following: “Guaranteed” installment agreements; “Streamlined” installment agreements; “In-Business” installment agreements; and “Partial Payment” installment agreements. These five types of installment agreements are analyzed with relevant citations to the U.S. Tax Code, Treasury regulations, court opinions, the Internal Revenue Manual, and IRS Revenue Procedures. A separate discussion is presented for requesting an agreement, including a line-by-line analysis of IRS Form 9465, Installment Agreement Request. A 7-page Table of Contents, a 15-page Table of Authorities, and an 8-page Index aids a tax professional’s scholarly understanding.