The following are actual cases that I demonstrated expert representation with exceptional results for my clients. The names of the taxpayer’s were changed to protect their identity.
IRS threatens to seize elderly couple’s Social Security Benefits
Dan and Carla owed the Internal Revenue Service $96,547 in back taxes as a result of a failed business. Both Dan and Carla were over age 65 and collected social security benefits. Dan continued to work in an effort to make ends meet. The Internal Revenue Service served a Notice of Intent to Levy Social Security Benefits to both of the taxpayers. Once Dan and Carla appointed me as their power of attorney, I immediately responded to the Internal Revenue Service’s threat of seizing the taxpayer’s social security benefits with a request for a collection due process hearing with the IRS Appeals Division. Under the law, the filing of a timely request for a collection due process hearing immediately stops all collection action until the taxpayer’s case is heard. When the Appeals Hearing took place, I submitted an offer in compromise which is a request to settle the total tax liability for a lessor amount. After going back and forth with the Internal Revenue Service we finally agreed on a settlement amount of $9,088.40 in complete settlement of the $96,547 due. The taxpayers were also able to keep 100% of their Social Security Benefits.
Real Estate Professional audited and denied rental losses
Bob’s full time employment was management of rental properties that he owned. These properties operated at a loss. Under the law, real estate professionals are allowed to deduct rental losses without limit. At the audit, the auditor as well as the auditor’s group manager took the position that Bob was not a real estate professional under the law and disallowed the losses and assessed Bob $11,252. The requirement under the law to be a real estate professional is that a taxpayer must prove that more than 50% of his or her time is devoted to real estate activities and have also work 750 hours in a given year. Therefore, on behalf of Bob I filed a protest with the Office of Appeals stating that I disagree with the auditors finding and requested an Appeals Hearing. While we were waiting for the appeals hearing date, I had Bob prepare a time log that was constructed from his repair receipts, rent collection receipts and other document that would prove he spent time managing these properties. The result was that he came out with more than 750 hours. This log was submitted to the Appeals Officer as an exhibit at the hearing. The trend in similar tax court cases is that the taxpayer generally loses if they didn’t keep a daily log during the year. However, the law states that the taxpayer may reconstruct a log after the fact. Giving the courts application of the law and the law itself, it would have been difficult to determine how this would have played out in court. As a result, the Appeals Officer found my testimony and the taxpayer’s log to be credible and completely threw out one year and split the second year 50/50, that resulted in the taxpayer assessment to be reduced down to approximately $3,500 down from the original $11,282
Small Business owner and wife owed IRS $45,355. Offer in Compromise accepted by IRS for $3,300
Bill and Denise own a small cleaning company and accrued $45,335 in taxes as a result of cash flow problems. In addition to helping out with the business Denise also worked part time for another cleaning company where she was treated as an employee and received a paycheck with taxes withheld. For a number of years, a local CPA prepared Bill and Denise’s taxes and served as their trusted tax advisor. When the couple’s tax problems became overwhelming for them, they appointed this CPA as their power of attorney to represent them before the IRS in this matter. The Internal Revenue Service sent the couple as well as the CPA a letter that stated, “Final Notice of Intent to Levy and Your Right to a Hearing”. By law if the taxpayers do not request the hearing within 30 days of the date of the letter, the IRS has the legal right to start levying and seizing property. The CPA failed to file, the request for a collection due process hearing. As a result, the Internal Revenue Service served a levy to Denise’s employer. Once I took over the case, I contacted the IRS and informed them, that the taxpayer’s are not in a position to pay this liability in full and that we would be submitting an offer in compromise to resolve this matter. We submitted a very complete, organized and meticulously prepared offer in compromise. The case was assigned to an offer examiner for review. This process was very brief and the offer examiner decided very quickly that the offer would be recommended for acceptance. Over the years, I have been complimented by many offer examiner as to excellent quality of my submission of offer in compromises. Shortly, after the offer examiner concluded the review, the taxpayers received a letter from the Internal Revenue Service that they have accepted their offer in the amount of $3,300.
Drywall Contractor owes IRS $139,190. Offer in Compromise accepted by the IRS for $2,000
Ron’s case was assigned to a Revenue Officer as he owed $84,283 for the tax returns he had filed. At the time, Ron had not filed tax returns for an additional 4 years. As a result, the Revenue Officer sent levies to all Ron’s customers. Ron appointed me as his power of attorney to represent him in this matter. I immediately contacted the Revenue Officer and made arrangements to file the 4 missing years of tax returns. I filed the additional 4 years of tax returns and Ron owed an additional $54,909 in taxes making the grand total of $139,190. Shortly, thereafter, I contacted the Revenue Officer and informed him, that the taxpayer had no way to ever pay off this liability. As a result, I informed the Revenue Officer, that I will be submitting an offer in compromise on behalf of the taxpayer to resolve the liability. On behalf of the taxpayer, I submitted a very complete, organized and meticulously prepared offer in compromise. This offer was so well put together, I never heard from an offer examiner I just received a letter from the Internal Revenue Service that my offer in compromise in the amount of $2,000 was accepted in full satisfaction of the $139,190 tax liability. During the pendency of this offer, I received a letter from the Internal Revenue Service-Automated Collection Support stating,” Final Notice of intent to Levy and your right to a hearing” for the 4 additional returns that were filed. To further protect my client, I filed a request for a collection due process hearing that legally stops the IRS from taking any enforced action until the taxpayer has their hearing. Once the offer was accepted, I received a summary notice of determination from the IRS Appeals Office that the case is resolved as the IRS has accepted the Offer in Compromise.
Recovering Addict settles approximately $50,000 in Tax Debt for $2,160
Sally became addicted to narcotics and alcohol for about 10 years after a divorce. During this dark period in Sally’s life she didn’t pay taxes for eight years and accumulated approximately $50,000 in tax debt. Sally became sober and narcotic free and made the decision to take her life back. Part of getting her life back was eliminating the IRS from her life. Originally, she hired a national tax resolution firm to handle her case. Shortly, thereafter she received a letter from me offering her a free consultation regarding her matter. During this consultation, I evaluated her financial information and determined that she would never be able to pay this tax liability in full. I recommended that she would be a good candidate for an offer in compromise. I calculated what I believed the minimum offer in compromise range would be. I indicated a range between $2,500 and $5,000. Sally felt very comfortable with my proposed solution as well as me personally. As a result, she hired me to represent her before the Internal Revenue Service and terminated the agreement the national tax resolution firm. I prepared a very complete, organized and meticulously prepared offer in compromise. As a result of the excellent quality of the offer in compromise package prepared the investigation by the Internal Revenue Service was very brief. The Internal Revenue Service sent a letter stating that they have accepted our offer in compromise of $2,160 in complete satisfaction of the approximately $50,000 tax liability.
Non-Filer Finish Carpenter settles $172,729 in Tax debt for $3,000
Lou didn’t file income tax returns for 11 years. When a taxpayer does not file a tax return and the IRS has information about the taxpayer’s income, the IRS can prepare a tax return for a taxpayer without their consent. That is exactly what the IRS did in Lou’s case. Once, the IRS prepared these returns and assessed a tax liability in the amount of $172,729, the Revenue Officer sent out levies to all of the companies that ever sent Larry a 1099. Lou came to my office for a free consultation by my invitation in a letter I sent him. At this consultation, I explained to Lou that the levies sent to his customer were not continuous like a wage levy and only attached to what his customer owed him at that point. One of his customers was hesitant about hiring Lou for future work as a result of this levy. I produced a copy of the law pertaining to levies so Lou could continue to work for this customer. I reviewed Lou’s finances and recommend that he files an offer in compromise. I also advised him, that the IRS may require him to file original tax returns for the 11 years he didn’t file, because the returns are considered substitute for returns prepared and filed by the IRS not by him. I indicated that I would approach the IRS about waiving this condition. Lou felt comfortable with my recommendations as well as me personally and appointed me as his representative before the IRS. I contacted the Revenue Officer assigned to Lou’s case and explained to her, that Lou didn’t have all his income and expense documents to file for the last 11 years. I requested that the filing requirement for the last 11 years be waived because I wanted to file an offer in compromise and it would expedite the resolution of the case. My request for waiving the filing requirement for the last 11 years was granted. Shortly thereafter, I submitted a detailed, organized and meticulously prepared offer in compromise to the Revenue Officer. As a result of the excellent work quality on the offer in compromise, the IRS investigation was very brief. Shortly thereafter, we received a letter from the IRS stating that they have accepted our offer in compromise in the amount of $3,000 in complete satisfaction of the $172,729 tax liability.
Truck Driver owes $233,130. Submits offer in compromise for $2,500. Offer denied by IRS. Filed Appeal and IRS decision reversed to accept $2,500 in complete satisfaction of $233,130 liability.
Sam a self-employed long distance truck did not file tax returns for 7 years. Sam was referred to me by another self-employed long distance truck driver that I helped with an IRS matter that resulted in him have the IRS accept an offer in compromise some years ago. The IRS prepared substitute for returns for a few of the years Sam didn’t file for. Well aware of the IRS position, that all tax returns must be filed in order for them to process an offer in compromise, I recommended to Sam that we file all 7 years of tax returns which we did. Sometime after all these returns were filed the IRS sent a letter stating, “Notice of Intent to Levy and Your Right to a Hearing”. In order to protect Sam from levy and seizure by the IRS, I promptly filed a request for a collection due process hearing which legally stops the IRS from taking any action until the taxpayer has their Appeals Hearing. When the case went to Appeals, I indicated that my proposed resolution of Sams matter was to submit an offer in compromise. Shortly thereafter, I submitted detailed, organized and meticulously prepared offer in compromise that the Appeals Officer forwarded to the IRS Collection Division for consideration. The result of the IRS Collection Division’s determination was that the offer in compromise was denied as Sam had the ability to full pay the liability. As a result of this case already in Appeals the offer in compromise would automatically be reviewed by the office of Appeals. In an effort to represent Sam’s best interest at this subsequent Appeals Hearing, I submitted a letter stating that the IRS position is incorrect because the IRS employee evaluating the offer in compromise erred while applying the provisions of the Internal Revenue Manual (IRS Procedure Manual). In my letter, I outlined a total of 5 instances where the IRS employee erred in applying the provisions of the Internal Revenue Manual. The Office of Appeals reversed the IRS’s position that Sam could full pay the liability of $233,130 in full and ruled that our original offer in compromise in the amount of $2,500 be accepted in complete satisfaction of the liability of $233,130.
Union Steel Worker owes $55,000 and settles for $3,300
Mark a union steel worker didn’t file tax returns for 5 years. The IRS had information about Mark’s income and prepared substitute for returns for a few of the years. Once the IRS has an assessment of taxes against a taxpayer, eventually the IRS can enforce collection by levy and seizure of property, If the taxpayer does not assert their rights. Mark missed his opportunity to file an appeal and the IRS served a continuous levy on his wages. Mark came in for a free consultation that I that I offered via mail. During the consultation, I advised Mark they we could get the levy released by filing the unfiled tax returns and providing a financial statement to the IRS with a proposal for resolution. I further explained, that the resolution would most likely be a payment agreement or an offer in compromise. Mike felt comfortable with my proposed resolution as well as me personally. Once appointed as Mark’s representative, I contacted the Revenue Officer and requested a release of wage levy once I file the unfiled tax returns and furnish a financial statement with a proposed resolution. The Revenue Officer agreed to these terms. Once I filed the tax returns and submitted the financial statement with my proposed resolution which was an offer in compromise, the Revenue Officer released the levy. Shortly after the wage levy release, I submitted a very detailed, organized and meticulously prepared offer in compromise. The IRS investigation period was very brief as a result of the excellent quality of the preparation of the offer in compromise package. Shortly thereafter, we received a letter from the IRS indicating that they have accepted our offer in compromise of $3,300 in full satisfaction of the $55,000 liability.
Self Employed Consultant owes $178,731. Files offer in compromise for $9,819 and denied by IRS. Decision overturned on Appeal and Offer accepted for $9,819 in complete satisfaction of $178,731 liability.
Connie a self-employed consultant accrued $178,731 in taxes as a result of a downturn in her industry. Connie responded to a letter I sent her offering a free consultation regarding her matter with the IRS. During the consultation, I learned that Connie’s income was progressively diminishing over the last few years and had no prospect of turning her circumstances around in the near future. I reviewed Connie’s finances and recommended that she file an offer in compromise. Connie agreed with my proposal and appointed me as her representative before the Internal Revenue Service. Once I filed the offer in compromise, the case was assigned to an Offer Specialist at the IRS. The Offer Specialist overstated the value of Connie’s assets by approximately $100,000 that resulting in the Offer Specialist requesting that Connie either increase her offer from $9,819 to $133,822 or withdraw her offer that waives her appeal rights. I recommended to Connie that we do neither, but instead file an Appeal. Therefore, I prepared a formal protest of the Offer Examiner’s findings stating that the values that were placed on Connie’s assets were significantly overstated. Once this case went to Appeals, I submitted additional documentation verifying the values of Connie’s assets and updated information regarding Connie’s present financial condition. Once Appeals reviewed the case, along with the additional information I submitted as part of the Appeals Hearing, Appeals overturned the IRS’s decision and ruled that the offer in compromise for $9,819 be accepted in full satisfaction of the liability of $178,731.