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Offer in Compromise

Tax Court – No IRS abuse in rejecting offer-in-compromise where taxpayer had cash and receivables

Tax Court – No IRS abuse in rejecting offer-in-compromise where taxpayer had cash and receivables

Strong, TC Memo 2016-70 The Tax Court has upheld IRS’s rejection of a taxpayer’s offer-in-compromise (OIC) that was based on doubt as to collectibility. The Court rejected the taxpayer’s argument that IRS abused its discretion by considering his business receivables as business assets for purposes of the OIC.  Click here for the Opinion of the […]

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District Court – statute of limitations on collection extended by taxpayer bankruptcy, offer in compromise

District Court – statute of limitations on collection extended by taxpayer bankruptcy, offer in compromise

Fields, (DC NM 3/17/2016) 117 AFTR 2d ¶ 2016-528 A district court has approved IRS’s calculation of an extension of the statute of limitations (SOL) on collection based on the taxpayer’s bankruptcy and his submission of an offer in compromise. It also approved IRS’s foreclosing on its liens on the taxpayer’s property that arose from […]

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Revised Offer in Compromise Booklet and Application – Updated Allowable Living Expense Standards for 2016

Revised Offer in  Compromise Booklet and Application – Updated Allowable Living Expense Standards for 2016

Revised Offer in Compromise Booklet and Application Coming The 2016 revision to Offer in Compromise Booklet Form 656-B will be available for download on Monday March 28. The booklet contains necessary forms and instructions for submitting an Offer in Compromise. Use of earlier versions may result in a delay in the processing of Offer applications. Information […]

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Joint Explanatory Statement of the Committee of Conference – Tax provisions in the “Fixing America’s Surface Transportation (FAST) Act”

Joint Explanatory Statement of the Committee of Conference – Tax provisions in the “Fixing America’s Surface Transportation (FAST) Act”

Joint Explanatory Statement of the Committee of Conference On December 3, one day before the expiration of the previously-passed temporary funding measure, both chambers of Congress passed H.R.22, the “Fixing America’s Surface Transportation (FAST) Act”. The bill was sent to President Obama for his expected signature. In addition to authorizing federal surface transportation programs through […]

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Washington Alert – IRS and the Dirty Dozen; EITC Enforcement; Qualified Zone Academy Bonds; Offer in Compromise Booklet Revised; Middle Class Economics

Washington Alert – IRS and the Dirty Dozen; EITC Enforcement; Qualified Zone Academy Bonds; Offer in Compromise Booklet Revised; Middle Class Economics

IRS on Feb. 9 published its complete list of the 2015 “Dirty Dozen” tax scams. (IR 2015-26) Commencing on Jan. 22, the agency cited one scam each business day in order to place more emphasis on each of the scams. The tax scams included the following – phone scams; phishing; identity theft; return preparer fraud; […]

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Washington Alert – US and Netherlands sign IGA; Hatch and tax reform; New IRS Offer in Compromise Forms

Washington Alert – US and Netherlands sign IGA; Hatch and tax reform; New IRS Offer in Compromise Forms

The U.S. and the Kingdom of the Netherlands, in respect of Curaçao, on Dec. 16 signed an intergovernmental agreement to improve international tax compliance and to implement the Foreign Account Tax Compliance Act. The agreement can be found at treasury.gov/resource-center/tax-policy/treaties/Documents/FATCA-Agreement-Curacao-12-16-2014.pdf Sen. Orrin Hatch (R-UT), the new chairman of the Senate Finance Committee, continues to flesh […]

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Request for installment agreement doesn’t preclude issuance of levy intent notice

Request for installment agreement doesn’t preclude issuance of levy intent notice

Eichler, (2014) 143 TC No. 2 The Tax Court has held the Code provision that prohibits IRS from making a levy while an offer for an installment agreement is pending does not prohibit IRS from issuing a notice of intent to levy while such an offer is pending. It also held that IRS’s decision not […]

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Grace period applies for increased OIC application fee

Grace period applies for increased OIC application fee

IRS’s Small Business/Self-Employed Division (SBSE) has issued a Memorandum that provides a grace period for imposing the increased application fee for submission of an offer-in-compromise (OIC). Although the application fee increased to $186 from $150, effective Jan. 1, 2014, IRS will accept and process taxpayers’ OICs with a lesser application fee through Feb. 3, 2014. […]

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Final regs increase installment agreement, offer-in-compromise fees

Final regs increase installment agreement, offer-in-compromise fees

IRS has issued final regs that increase the user fee for entering into an offer-in-compromise and some fees for entering into, restructuring, or reinstating an installment agreement.  The new fees will apply starting Jan. 1, 2014.  T.D. 9647, 12/02/2013, Reg. § 300.1, Reg. § 300.2, Reg. § 300.3 The final regs adopt, without change, proposed […]

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Case Alert: Chief Counsel attorney reviewing offer-in-compromise wasn’t “de facto” Appeals officer

Case Alert: Chief Counsel attorney reviewing offer-in-compromise wasn’t “de facto” Appeals officer

The Tax Court, in Ronald Isley v. Commissioner, (2013), 141 TC No. 11,  has concluded that the referral of an offer-in-compromise (OIC) to the Chief Counsel Office did not result in either the Chief Counsel Attorney becoming the “de facto” Appeals officer or a violation of the “impartial officer” requirement under Code Sec. 6330(b)(3), or […]

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Proposed Regulations would increase installment agreement, offer-in-compromise fees

Proposed Regulations would increase installment agreement, offer-in-compromise fees

Just when you thought it was safe, . . .  IRS has issued Proposed Regulations (“Regs”) that would increase the user fee for entering into an offer-in-compromise and some fees for entering into, restructuring, or reinstating an installment agreement. The new fees will apply starting Jan. 1, 2014. The proposed regs are Prop Reg § […]

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What are your chances for being audited? IRS’s 2012 data book provides some clues

What are your chances for being audited? IRS’s 2012 data book provides some clues

IRS has issued its annual data book, IR 2013-32, 2012 Data Book, which provides statistical data on its fiscal year (FY) 2012 activities. As this article explains, the data book provides valuable information about how many tax returns IRS examines (audits) and what categories of returns IRS is focusing resources on, as well as data […]

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IRS Guidance regarding student loan payments and delinquent tax liabilities: effect on Offer in Compromise

IRS Guidance regarding student loan payments and delinquent tax liabilities: effect on Offer in Compromise

Editor’s Note:  IRS has issued new rules regarding Offers in Compromise and we have blogged them in two articles, the first of which was “Surprise, Surprise Surprise: IRS Announces More Flexible Offer-in-Compromise Terms to Help a Greater Number of Struggling Taxpayers Make a Fresh Start.” and the second being “Let’s Make a Deal!!  Time to […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney