IRS Offer in Compromise: A Treatise for Attorneys, CPAs, Accountants & Tax Preparers 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.
IRS Offer in Compromise: A Treatise for Attorneys, CPAs, Accountants & Tax Preparers begins in Chapters 1 thru 3 with an overview of the U.S. Tax Code, Treasury Regulations, court rulings, Internal Revenue Manual, and IRS Revenue Procedures. Next, the IRS collection apparatus is explained, including bank levies, wage garnishments, and federal tax liens. Chapter 4 discusses the IRS’ authority, motivation, and basis to eliminate back-taxes, including doubt as to collectibility offers, effective tax administration offers, and doubt as to liability offers. This book is focused on doubt as to collectibility offers only. An overview of the Offer in Compromise process is provided in Chapter 5. Chapter 6 considers the seminal question: who should submit the Offer in Compromise application? Payment issues associated with an Offer in Compromise application are considered in Chapter 7. Chapter 8 analyzes the key issue of whether the Offer in Compromise application is “processable” and qualifies for further review. Chapters 9 thru 12 address the calculation of the minimum amount that a taxpayer must offer to eliminate all back-taxes. Chapter 9 presents the secret formula for calculating the lowest offer amount acceptable to the IRS, including a discussion of the “reasonable collection potential” or RCP.
Chapter 10 explains the asset valuation component of the formula. The income and expense components of the formula are discussed in Chapters 11 and 12 respectively. Chapter 13 provides a line-by-line analysis of the essential document – IRS Form 656, Offer in Compromise. Chapters 14 and 15 provide a line-by-line analysis of IRS Forms 433-A & B (OIC), Collection Information Statements. Chapter 16 considers the need for a “collateral agreement.” Chapter 17 explains a taxpayer’s obligations during the IRS investigation of an Offer in Compromise. “Terminating” a pending offer is considered in Chapter 18. “Withdrawing” a pending application is reviewed in Chapter 19. Chapter 20 analyzes the IRS’ decision whether to “return” an offer, including returning unprocessable applications and processable applications. Chapter 21 discusses the IRS analysis behind “rejecting” an Offer in Compromise application. The IRS’ decision process in “accepting” an Offer in Compromise application is explored in Chapter 22.
The taxpayer’s duties post-acceptance are reviewed in Chapter 23. Chapter 24 examines a taxpayer’s “default” of the accepted agreement’s terms. Chapter 25 explores a taxpayer’s right to receive tax refunds. Chapter 26 explains a taxpayer’s appellate right to review an IRS rejection. Chapters 27 thru 29 discuss an Offer in Compromise’s affect upon levies, garnishments, installment agreements, and trust fund and trust fund recovery penalties. Chapters 30 and 31 encompass a host of miscellaneous issues, including public disclosures, assessment period and collection period extensions, and bankruptcy. Chapter 32 explains powers of attorney, including a line-by-line analysis of IRS Form 2848, Power of Attorney.
Finally, Chapter 33 reviews third-party authorizations including a line-by-line analysis of IRS Form 8821, Tax Information Authorization.
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