Dec 19, 2007

Your tax debt- Part 17 – Installment Agreements when you owe more than $100,000 to the IRS

IRS agreements are especially difficult when you owe over $100,000 in tax, penalties and interest. This is due to the IRS special enforcement procedures at that level of tax debt.

If you owe that much to the IRS they will send you to one of two places (and neither are good):

1. The Automated Collection System- High Liability Unit, or
2. A local Revenue Officer who will be assigned your account to personally enforce collection

There are special IRS procedures outlined in the Internal Revenue Manual (“IRM”) and the Law Enforcement Manual (unpublished and known as the “LEM”), which include, but are not limited to the following:

–A complete review of your financial situation and documentation (as per normal procedures) and a review of your:

• Credit report
• DMV records
• Accurint program search and follow up- this is an asset/credit availability search as well as a detailed review of relatives, friends, neighbors, etc. that you may have given assets
• Property records
• Tax records
• A review of any suspected related returns and related taxpayers returns

Obviously, this is an intrusive investigation that should not be taken lightly. If you over $100,000 in tax debt, you should not represent yourself. You should consult a competent tax professional for all of your options and questions.

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