Many tax professionals concentrate on tax planning and compliance, along with (perhaps) the audit of tax returns they have prepared. Some venture into the “controversy” world of resolving IRS tax problems.
On Mar. 26, 2020, the IRS released its new "People First Initiative" as part of its continued efforts to provide relief to taxpayers in light of COVID-19. Further guidance continues to be rolled out. For taxpayers who are currently under audit, in an appeal before the IRS Independent Office of Appeals, or the United States Tax Court, or are now in collections with the IRS, this offers a unique opportunity to limit their liability. It also comes with substantial pitfalls for advisors if they fail to fully appreciate the limits of the relief being provided by the IRS.
Tax professionals must recognize key procedural tactics and planning methods for taxpayers seeking to avoid collections and compliance actions. For those taxpayers already subject to IRS enforcement actions or currently under audit, the time is now to revisit collection solutions based on the impact of COVID-19 and the current state of the economy. Tax Problem Resolution work (or “controversy” work) consists, generally, of representing clients in audits (and possible appeal of an adverse audit); and representing clients with tax debts before the IRS Collections Division.
Major Topics Covered :
- Installment Agreements
- Requesting Installment Agreements
- In-Business Trust Fund Installment Agreements
- Effect of an Installment Agreement
Some also represent taxpayers before the United States Tax Court, District Courts, Bankruptcy Courts, and some handle criminal investigations and trials. Knowing the rules, what you can and cannot do, what IRS can and cannot do, is all part of the game and if you play it well, you can resolve clients’ tax debt problems ethically, successfully, and profitably.
