The Accountant's Guide to IRS Collection

A Step-by-Step Guide to Resolving Your Client's Tax Debt - 2nd Edition

Eric Green

• Publisher: TG Publishing LLC
• Year: 2019
• eBook ISBN: 9781087944081
• Topic: Business
• Subtopic: Taxation
• Index: Business

The IRS Collection Division inventory continues to explode, with more than 14 million accounts in the IRS Collection Division inventory at the end of 2016. It is estimated that nearly 1 out of 15 taxpayers owes the IRS money. Accountants are well-placed to take the lead in helping taxpayers resolve their outstanding issues while adding a valuable revenue stream to their existing practices, yet almost none do. Why? The reason is that most accountants neither understand the IRS Collection process nor how to calculate a taxpayer’s ability to pay and resolve the situation the way the IRS does. But that is about to change!

Attorney Eric Green is a tax attorney and the founder of a boutique tax law firm with offices in Connecticut and New York. He is a national speaker, a columnist for the Journal of Tax Practice & Procedure, and a pundit on everything IRS Enforcement. In this guide Attorney Green walks you through the entire IRS Collection process: from initial client call to Offer-in-Compromise acceptance letter. Through his examples, ‘Hot Tips’ and actual client stories, Attorney Green will teach you many of the inside secrets that will help you become an IRS Collection master and help your clients resolve their stickiest collection issue. The guide includes a checklist practitioners can use in their daily practice, and dozens of samples and exhibits. Whether you have handled many cases before, or never even spoken to the IRS, this guide will teach you the IRS collection process, how to handle clients and IRS personnel, and where the opportunities are to resolve your client’s issue.

Exhibits

Exhibit Number	Exhibit
1	CP-516: Notice of Missing Return
2	Administrative Summons
3	CP-501: Billing Notice
4	CP-503: Reminder Notice
5	CP-504: Threat To levy
6	Letter 11: Final Notice of Intent to Levy & Taxpayer’s Right to a Hearing
7	Form 12153: Request for a Collection Due Process or Equivalent Hearing
8	IRS Account Transcript
9	Sample retainer Agreement
10	IRS Form 2848 – Power of Attorney
11	IRS Form 1040-ES – Estimated Tax Payment Vouchers
12	IRS Letter 3172 – Notice of Federal Tax Lien
13	IRS Form 12277 – Application for Withdrawal of Filed Notice of Federal Tax Lien
14	IRS Form 14135 – Application for Certificate of Discharge of Property from Federal Tax Lien
15	IRS Form 14134–Application for Certificate of Subordination of Federal Tax Lien
16	Department of Justice Court Filing of Suit to Convert Federal Tax Lien to Judgment
17	IRS Form 668-A – Notice of Levy
18	IRS Form 9465 – Installment Agreement Request
19	IRS Form 433-A – Collection Information Statement for Wage Earners and Self-Employed Individuals (Field Collections)
20	IRS Form 433-F – Collection Information Statement (ACS Form)
21	IRS Form 433-B – Collection Information Statement for Business
22	IRS 433-H – Installment Agreement Request and Form Collection Information Statement
23	IRS Form 433-D – Installment Agreement
24	IRS Letter CP-523 – Notice of Intent to Terminate Your Installment Agreement
25	IRS Form 9423 – Collection Appeal Request
26	IRS Letter 4223 – Case Closed as Currently Not Collectable
27	IRS Offer-in-Compromise Booklet
28	Sample IRS Allowable Standard Expenses for Collection
29	IRS Form 4180 - Report of Interview with Individual Relative to Trust Fund Recovery Penalty or Personal Liability for Excise Taxes
30	IRS Letter 1153 – Notice of Proposed Trust Fund Assessment
31	IRS Form 2751 - Proposed Assessment of Trust Fund Recovery Penalty Waiver
32	IRS Letter 4837 – Letter Confirming Appeals has Received the Taxpayer’s Case
33	IRS Form 12257 – Summary Notice of Determination, Waiver of Right to Judicial Review of a Collection Due Process Determination, Waiver of Suspension of Levy Action, and Waiver of Periods of Limitation in Section 6330(e)(1)
34	United States Tax Court Petition Kit
35	IRS Form 9423 – Collection Appeal Process
36	IRS Form 12661 – Disputed Issue Verification for Audit Reconsideration
37	IRS Form 656-L – Offer in Compromise (Doubt as to Liability) booklet
38	IRS Form 8857 – Request for Innocent Spouse Relief
39	IRS Form 911 – Request for Taxpayer Advocate Service Assistance
40	IRS Form CP-40 – Notice of Account Transfer to Private Debt Collector
41	Notice from the Private Debt Collector that the Taxpayer’s account has been transferred to it for collection
42	Letter from the Private Debt Collector that the taxpayer’s payment agreement has been established
43	IRS Letter 508C - Notice of certification of a seriously delinquent federal tax debt to the State Department

THIS IS PROVIDED AS A SAMPLE ENGAGEMENT LETTER. IF YOU CHOOSE TO USE THIS AS A TEMPLATGE PLEASE BE SURE TO READ THROUGH IT CAREFULLY AND ADJUST THOSE TERMS TO FIT YOUR FIRM AND YOUR ENGAGEMENT.

July ____ , 2019

Via Email:_________________

Name

Address

City, State, Zip

Re: Client Retention Agreement

Dear MS. CLIENT:

We are pleased you have requested that Green & Sklarz LLC (“G&S” or “Firm”) provide you with representation as set forth below. We would appreciate receiving written acknowledgement of this agreement for our files. We feel that it is in the best interest of our clients that they be fully informed of our billing practices. The purpose of this letter, therefore, is to set forth the scope of our engagement to represent you, to set forth the financial arrangements regarding our engagement and to verify our agreement of the foregoing:

7.Scope of Engagement

Subject to the terms and conditions herein, including without limitation advance payment of the retainer and a signed copy of this agreement G&S will perform the services which you requested and, more specifically, to represent you before the Internal Revenue Service (the “Engagement”).

2.Fee for Representation

Our billing practice is to charge for our services based on the hourly rate of the representative involved. We bill in increments of no less than 1/10 of one hour. Please note, we bill for all services our office provides, including but not limited to: correspondence, telephone calls, document preparation, research, electronic research, inter-office conference, meetings, etc. We use the amount of time devoted to a matter by a particular representative at that representative’s hourly rate. These hourly rates are based upon experience, expertise and standing. In addition, we try to use associate, assistant an...

Table of contents

• Cover Page
• Copyright Page
• Table of Contents
• About the Author
• Why This Book?
• Acknowledgments
• The IRS Collection Process
• The Collection Client
• Federal Tax Liens
• The Federal Tax Levy
• Collection Alternatives: Offers, Installment Agreements, Uncollectible Status, and Bankruptcy
• Payroll Taxes and Personal Liability
• Collection Appeals
• Challenging an Assessed Tax
• The Taxpayer Advocate Service
• Private Debt Collectors & Passport Suspension/Revocation
• Checklist: New Collection Client
• IRS Abbreviations Cheat Sheet
• Exhibits