Recently in Tax Debt Category

Collection Due Process (CDP) Hearing Requests Sent to the Wrong IRS Office Creates Tax Problems

January 17, 2014,

For the IRS to issue a tax levy to garnish bank accounts, wages or other assets it, generally, must first issue a Collection Due Process or CDP Notice. The CDP Notice is required by Internal Revenue Code Section 6330. The CDP notice is generally issued by the IRS on either Form LT-11 or Letter 1058, and it is titled "Notice of Intent to Levy and Right to Request A Hearing." These letters give a taxpayer, who owes the IRS money, 30 days to file a request for a hearing with the Internal Revenue Service's Appeals Division. More on this in a moment.

If the taxpayer doesn't request a Collection Due Process hearing IN WRITING within the 30-day period, then the IRS may immediately begin seizure of bank accounts, accounts receivable, or any other assets. The IRS may even seize someone's home, although this requires a lot more paperwork, and the approval of a federal district court judge.

An IRS internal document known as an IRS Program Manager Technical Assistance recently provided information on what will happen if the request for a CDP hearing is mailed timely to an incorrect office. The short answer is that the CDP hearing will be denied, and the IRS is legally free to begin levies and seizures. However, a taxpayer in this situation is, generally, permitted an "equivalent" CDP hearing; however, an equivalent CDP hearing does not carry with it the right to appeal to the United States Tax Court. It is only a timely filed request for a CDP hearing that will be appealable to the Tax Court if the IRS Appeals decision is not to the taxpayer's liking.

In order for a CDP hearing request to be timely it must either be received by the correct IRS office within 30 days of the date of the CDP notice, OR be mailed timely to the correct office. In order to prove that the request has been mailed timely the best practice is to mail it by certified mail, return receipt requested, and obtain a stamp from the Postal Service showing the date on which the CDP request was mailed. Alternative delivery services such as FedEx may be used also, but the rules are a bit tricky.

Typically the CDP hearing requests must be sent to one of the four automated collection sites (ACS) maintained by the IRS around the country. However, cases assigned to an IRS revenue officer require that the request be sent to the Revenue Officer. In any event, the letter itself will explain where the CDP request should be sent, and if those instructions are followed, there won't be a problem.

A CDP hearing is a valuable right which should almost never be waived. At a CDP hearing the Appeals Officer will consider:

• Collection alternatives such as installment agreement or offers in compromise.
• Whether the IRS has followed all laws and procedures
• Subordination or discharge of a lien.
• Withdrawal of Notice of Federal Tax Lien.
• Innocent Spouse defenses
• In limited situations, the correctness of the tax liability.

So if you receive a Notice of Intent to Levy and Right to Request a Hearing, make sure that you request a hearing within the 30-day time frame.

Contact our experienced criminal tax attorneys at 1- 800 Tax Litigator for a confidential consultation to discuss available options if you have been contacted by the IRS in connection with civil or criminal tax fraud or tax evasion, or any other high stakes tax problem.

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Important Offer in Compromise (OIC) Tip from a Senior IRS Collection Official

November 6, 2013,


An Offer in Compromise (OIC) can be one of the best ways to avoid an IRS tax levy, and to reduce your tax debt if you have fallen far behind. Earlier this month I was speaking with a senior IRS collection official about Offers in Compromise, and he brought up an iMoney Pic.jpgnteresting point. First, a little background. The IRS will allow taxpayers to reduce the amount of their tax debts if the IRS concludes that it is unlikely that the tax debt will be paid during the remaining time the IRS has to collect. This time period is referred to as the Collection Statute Expiration Date or CSED. If the tax can't be paid during the CSED then the IRS may accept a settlement amount.

The IRS calculates this settlement amount, by adding the taxpayer's net realizable equity in assets to the amount collectible from future expected income after payment of "necessary" living expenses. This is known as the reasonable collection potential or RCP. The amount collectible from future expected income is determined based upon the period over which the taxpayer proposes to make payments. If the payment period is from 1 to 5 months then the future income is determined over a 12 month period. On the other hand, if the taxpayer wishes to make payments over more than 5 months (up to a maximum of 24 months) then the future income is calculated over the entire 24 month period.

To take a simple example. Assume a taxpayer owes the IRS $300,000, and has assets of $25,000. In addition, she has monthly income, after necessary living expenses, of $2,000. If the taxpayer can pay the offer amount in 5 months or less than the RCP, the amount offered, would be $49,000 ($25,000 + 12 months x $2,000). On the other hand, if the taxpayer needs more than 5 months, then the RCP would be $73,000 (25,000 + 24 months x $2,000).

Now for the tip from the IRS collection official with whom I spoke. The payments made over the 24 months do not need to be equal in amount! So in the above example it would not be necessary to pay $3,041.67 per month ($73,000/24 months). Instead the IRS could accept monthly payments of $1,500 per month for 23 months with a balloon payment of $38,500 in the 24th month. Any other variation is possible, so long as $73,000 is paid by the 24th month. However, there can be no renegotiation once the OIC is accepted. So if the taxpayer defaults in month 24 because she can't afford the balloon don't expect much sympathy. Do expect that the IRS will want a credible explanation, and documentation of the taxpayer's ability to come up with the balloon payment. It may be friends or family, liquidation of assets (e.g. retirement accounts, real or personal property, etc.), forthcoming settlement, inheritance, wages, or the like. If the IRS financial analysis determines that the OIC cannot be funded, the offer will be rejected. The mere hope that things are going to get better won't cut it.

If you have tax problems, and you are considering an offer in compromise or another alternative to your tax problems call the tax lawyers at Brager Tax Law Group, A P.C.

Click here to Subscribe to the Free Online Publication, The Tax Terminator! The IRS is busy and so is the FTB and EDD. This publication, The Tax Terminator, will keep you abreast of events that are making the news and perhaps affecting you and/or your business.

California Franchise Tax Board (FTB) To Issue 475,000 Tax Levies for Delinquent Tax Debts

June 27, 2012,

If you or your clients have tax problems and owe California State income taxes, the Tax Man Cometh! The California Franchise Tax Board (FTB) is collecting delinquent tax debts through the Financial Institution Record Match (FIRM) program. FIRM uses automated data exchanges to locate bank accounts held by Californians who have tax debts. The FIRM program will match records on a quarterly basis in order to collect tax debts from both individuals and businesses. No financial institution doing business within the state of California is exempt from participating in the program. However, in rare cases temporary exemption or suspension of participation may apply. Banks that chose not to comply are subject to large fines each year. Accounts that are eligible for tax levies include checking and savings accounts, as well as mutual funds. FIRM is similar to the Financial Institution Data Match (FIDM) program, which is used to collect delinquent child support debt.

The FIRM program allows the FTB to use data obtained from banks to find assets and garnish bank accounts up to 100 percent of the amount owed. As of April, the FTB began to serve tax levies on the bank accounts of individuals who have delinquent balances, including penalties, interest, taxes and fees that have been identified through FIRM. With the help of the FIRM program, the FTB expects to issue 475,000 tax levies this fiscal year, a 75 percent increase from last year.

In order to avoid tax levies you or your tax lawyer should consider possible alternatives including installment agreements, offers in compromise and bankruptcies.

Data between FTB and FIRM can be exchanged in two ways. In the first method, information regarding open accounts is given directly to the FTB for the Board to match accounts with delinquent taxpayers. This method is only available to institutions that are unable to match the information against their own records. Institutions that do not qualify for the first method must match taxpayer information against their own records. Banks can choose to hire a third-party transmitter to aid in matching the data. Because the accuracy of the data is of the utmost importance, banks must verify matches from third-party services before submitting them to the FTB.

A 10-day holding period follows the issue of the tax levy to the bank. During this time, the taxpayer or a tax attorney on the taxpayer's behalf may negotiate the amount due or, if financial hardship is creating tax problems, discuss payment options. If the FTB levied an account in error, they will delay the garnishment while they verify the mistake and then issue a garnishment release notice. If the bank has already issued the payment, the Board will return the payment.

Continue reading "California Franchise Tax Board (FTB) To Issue 475,000 Tax Levies for Delinquent Tax Debts " »

Felony Criminal Tax Prosecution Goes Forward

December 20, 2011,

United States v. Quinn (D. KS 2011) is one of several recent felony tax prosecutions, not for tax evasion, but for violation of Internal Revenue Code Section 7202. IRC Section 7202 makes it a felony to willfully fail to collect, account for, or pay over any tax due. In this case Ms. Quinn failed to pay payroll taxes for 7 quarters between 2003 and 2005. She finally got around to paying them in 2010, apparently after the IRS had filed criminal tax charges against her. Ms. Quinn challenged the finding that she failed to pay employment and individual tax and argued that since she had subsequently paid the tax due the charges should be dismissed.old_ball_and_chain.jpg

The court wrote in its opinion that a person has failed to pay taxes if they have not paid the amount due as of the due date, regardless of whether the taxpayer has subsequently paid. In Ms. Quinn's case, she had recently paid the amounts due but this was not sufficient for the court to find her not guilty.

This does not mean that late payment of taxes will never prevent a criminal tax prosecution, and those who have not paid their taxes should seriously consider taking care of a tax problem before it turns into a criminal tax problem. Had Ms. Quinn gotten around to making full payment, or indeed even made good faith installment payments much earlier there is a chance that the case would never have gotten as far as it did.

Continue reading "Felony Criminal Tax Prosecution Goes Forward " »

Tax Attorney Blames OCD for Failure to File Business Income Taxes

March 25, 2011,

Tax lawyers representing a man accused of failing to file business income tax returns told the judge that obsessive-compulsive disorder was responsible for their client's tax problems, the Calgary Herald reported.

Business tax debt can sink a business; frequent issues tax attorneys are called to deal with include payroll tax problems and tax audits.
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That's not to say OCD is involved in the majority of the cases. But in this case, the man blames the condition for his inability to file business income tax returns. He faces 60 days in jail and a $10,000 fine if convicted of disobeying a court-issued compliance letter. The company, Harvest Brewing, is accused of not filing returns in 2004 and 2005. His attorney said Ronald Thomsen's personal taxes are up to date because they are easy to file and the taxes are deducted right from his pay.

But when it comes to the business taxes, his client's medical condition prevents him from dealing with the paperwork. The business taxes were about $45,000 a year in the five years prior to the years in question. However, Canada Revenue Agency does not know how much is now owed because they haven't received any documentation in years. The business's accountant has told Thomsen she would have the outstanding taxes filed by May but he has refused to turn over the paperwork.

That refusal is part of the medical condition, according to his tax attorneys.

Continue reading "Tax Attorney Blames OCD for Failure to File Business Income Taxes " »

"Little Fockers" Star has Tax Liens for $433K in Back Taxes to IRS, State of California Franchise Tax Board

March 23, 2011,

The Detroit News is reporting that Hollywood actress Teri Polo, perhaps best known for playing alongside Robert De Niro and Ben Stiller in "Meet the Parents," has a tax lien for $433,736.

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The former Playboy pinup landed the role after a string of TV show appearances, including "The West Wing." She is also appearing in "Little Fockers," which is in theaters this year.

-The Internal Revenue Service filed a tax lien against Polo in August in Kent County Delaware in August 2009, claiming she owes $114,843.95 in income taxes from 2007.

California claims she owes $91,748 for taxes in 2005 and 2006, according to a tax lien filed in Los Angeles County in 2008.

-A second IRS tax lien in Delaware also claims she owes $227,144.48 in back taxes for 2005 and 2006.

Polo blames her tax problems on a costly divorce and being unable to work while raising two young children. She reportedly has reached a deal with the IRS to repay the tax debt.

Continue reading ""Little Fockers" Star has Tax Liens for $433K in Back Taxes to IRS, State of California Franchise Tax Board " »

Wesley Snipes to Serve 3 Years for Failure to File Tax Returns

March 15, 2011,

CNN reports Hollywood actor Wesley Snipes is off to serve a three-year prison sentence for failing to file tax returns.

While simple non-filing of tax returns doesn't often result in criminal tax fraud charges being brought, in some cases, it may require being proactive, and consulting an experienced tax lawyer to prevent a tax problem from getting worse.
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Prosecutors alleged Snipes has earned $40 million since 1999 but filed no returns because of his involvement with a tax resisters group. Snipes denied membership in such a group and blamed his tax problems on an adviser. Jurors believed his contention that advisers were at fault when they acquitted him of more serious felony tax fraud and conspiracy charges. Still three years in jail can hardly be considered a vindication.

The New York Times reported the star of "Blade" and "White Men Can't Jump" will serve the sentence at a federal prison in Pennsylvania.

Continue reading "Wesley Snipes to Serve 3 Years for Failure to File Tax Returns " »

Southern California IRS Revenue Agent Pleads Guilty to Tax Fraud

March 14, 2011,

An IRS revenue agent has pleaded guilty to filing false tax returns, according to a report in the Los Angeles Times.

The 51-year-old defendant pleaded guilty to filing false returns for himself, as well as a number of relatives. In some cases, he admitted to filing returns for relatives without their knowledge and keeping the returns he received.

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In this case, the defendant, who was employed as a revenue agent for the Internal Revenue Service, filed false returns from 2003 to 2007, which claimed excessive deductions and failed to report some income. He worked as a revenue agent in Southern California until being placed on leave following his arrest in 2009.

He has agreed to pay $127,000 in restitution to the government and faces up to 9 years in federal prison at his sentencing, which is scheduled before a federal judge in Los Angeles on April 13.

He had been charged with threatening to harm agents who served a search warrant on his Santa Clarita home in 2009. However, those charges were dropped as part of the plea agreement.

Continue reading "Southern California IRS Revenue Agent Pleads Guilty to Tax Fraud " »

Bust of Bogus Tax Relief Company in Beverly Hills a Reminder to those Dealing with the IRS to seek Advice of Qualified Tax Lawyer

October 31, 2010,

Our tax attorneys noted the recent closure of American Tax Relief in Beverly Hills for fraud and misleading advertising that claimed the company could settle delinquent federal and state taxes for pennies on the dollar.
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We reported recently on our Tax Problem Attorney Blog when Roni Deutch ran afoul of the California Attorney General for advertising that was allegedly misleading. Those facing charges for tax evasion need solid legal advice and should not be misled. A tax lawyer can save a client thousands of dollars by protecting their rights in disputes with the IRS. However, finding a reputable tax dispute law firm is a critical first step in the process.

The Los Angeles Times reports that the Federal Trade Commission accuses American Tax Relief of bilking 20,000 customers out of $100 million with false claims about the company's ability to reduce their tax debt.

The FTC said the company used TV, radio and Internet advertising to claim it could settle tax debt with the IRS for less than what was owed. It also claimed it could remove tax liens, stop wage garnishments and successfully challenge bank and tax levies as well as property seizures and "unbearable monthly payments."

The husband and wife couple had been operating the company for over a decade and charged upfront fees of up to $25,000. The company's assets were frozen by a Chicago judge who issued a restraining order. And a receiver has been appointed to manage the company.

Despite earning more than $60 million form the business, the couple allegedly failed to pay their own taxes.

Investigators said the company provided an "essentially useless service" while pushing people further into debt instead of helping them address their tax problems with the IRS. The company charged thousands to client credit cards and stopped answering customer calls after receiving payment, according to investigators, who hope to recover restitution for the victims.

There has been no reports of whether either owner even had a law degree.

Continue reading "Bust of Bogus Tax Relief Company in Beverly Hills a Reminder to those Dealing with the IRS to seek Advice of Qualified Tax Lawyer " »

Tax Lady Roni Deutch’s Tax Resolution Company Sued by Attorney General

September 2, 2010,

According to a complaint (Part 1 Part 2) filed by the California Attorney General against a well known tax attorney Roni Deutch, she has violated numerous state consumer protection laws, along with the rules of professional conduct governing the conduct of all California attorneys, tax attorneys included. Roni Deutch is well known to viewers of her TV commercials promising to solve tax debt problems through offers in compromise, levy releases, and installment agreements.

The complaint makes many allegations including that:

* Roni Deutch advised clients that they may suspend their installment payments to the IRS once they have engaged her tax attorneys for tax debt resolution services. Deutch tells clients that once they retain Roni Deutch A P.C., the clients are not legally obligated to continue making installment payments to the IRS.

* Roni Deutch’s tax attorneys each regularly carry caseloads as high as 600 to 700 clients at one time, but during especially busy periods can service as many as 1,200 clients at one time.

* Roni Deutch tell clients that their success rate in resolving clients' back tax liability with the IRS is as high as 99%. In fact, her success rate is dramatically lower. In a majority of their clients' cases, Deutch never actually submits a request for tax debt relief. According to Deutch’s own figures, of those clients who retain her tax problem resolution law firm for the offer in compromise service, only 10% successfully receive an offer in compromise from the IRS.

* Roni Deutch solicits clients for her tax debt resolution services in a number of ways, including a television and radio advertising campaign. In these advertisements, Roni Deutch gives clients specific and non-representative examples of clients who have purportedly reduced their tax liability by as much as $150,000 by hiring Roni Deutch A P.C. At least some of these representations are false and misleading.

* The advertisements list a toll-free telephone number for consumers to call to receive a free "tax analysis." When consumers dial the telephone number listed, the "tax analysis" they receive is a sales pitch for Ronni Deutch’s tax problem resolution services from her sales agents, who are hired solely for their ability to sell. Their sales agents are not required to have any background, experience, or familiarity with federal tax law or the IRS.

Of course these are only allegations, and not proven facts, and Roni Deutch has released a statement saying she will fight the suit. If the allegations are true, however, it will probably mean the end of Ronni Deutch’s tax problem resolution service business, and probably her career as a tax attorney as well. The complaint is a cautionary tale for those taxpayers with tax problems. As in all areas of life if the promises sound too good to be true then it’s time to take a closer look.

If you have a tax problem in excess of $75,000, and would like to learn more about your options contact the tax litigation attorneys at Brager Tax Law Group, A P.C.

FBARs and More FBARs

May 11, 2010,

I just returned from an ABA meeting of tax lawyers in Washington, D.C. It seemed like all of the tax attorneys (or at least the tax litigation attorneys) could find nothing to talk about, but Foreign Bank Account Reports, i.e. TDF 90-22.1 (FBARs),voluntary disclosures, and offshore bank accounts. Over a period of two days I spend at least 8 hours in formal meetings with other tax lawyers talking about FBARs, and more hours over drinks and food talking about FBARs. The main theme was that the rules surrounding tax amnesty are being enforced more harshly than many tax attorneys had hoped would be the case. A few highlights of what I heard, the good, the bad, and the ugly:

• 225 revenue agents have been assigned to conduct civil tax audits in voluntary disclosure of offshore bank account cases
IDRs (Information Document Requests) can be expected in most offshore bank account cases within the next few weeks
• The goal of IRS management is to close a “substantial portion” of the tax audits by the end of 2010
• IRS has started to identify taxpayers who made quiet voluntary disclosures of their offshore bank accounts, and these cases will be worked as “full blown” civil tax audits—meaning these taxpayers are potentially subject to multiple 50% FBAR penalties
• It is too soon to tell how post Oct. 15th voluntary disclosures will be treated for civil tax purposes—speculation continues to center on 25 to 35 per cent
• IRS has rolled out a “third generation” IDR which the IRS believes is more streamlined
• Basis issues will be negotiable, i.e. if basis information is unavailable revenue agents will likely accept reasonable alternatives, e.g. value security as of 1/1/2003
• Even if a timely 2008 FBAR was filed, if the highest offshore bank account value was in 2008, the 20% penalty will be calculated based upon 2008 value
• Revenue Agents do not “currently” have the authority to waive de minimus violations – there is no such thing as being half pregnant.

If you have a foreign financial account call the tax litigation lawyers at Brager Tax Law Group, A P.C. to get more information on voluntary disclosures and FBARs.

Tax Lien Foreclosure Moves Forward on Home

March 25, 2010,

When the IRS files its federal tax lien it attaches to all of the taxpayer’s assets, including his home, bank accounts, cars and personal belongs. The federal tax lien ensures that if real property is sold any proceeds will go to the IRS to pay its tax lien. The IRS can also foreclose on its federal tax lien, and sell any property that the taxpayer owns.

There is a myth that the IRS won’t seize and sell a taxpayer’s home. Like most myths there is a grain of truth to it. In order to sell a taxpayer’s primary residence the IRS must obtain an order from a federal district court pursuant to Internal Revenue Code Section Section 6334(a)(13). However, if negotiations break down, or the statute of limitations on collection is about to expire, the IRS can and will seek a court order, and most courts will grant such orders. This is one reason why it is critical, especially in large dollar cases, that taxpayers obtain advice from a tax attorney with experience dealing with these types of tax problems.

A recent case from South Dakota illustrates that tax problems do not get better with age. United States v. Boscaljon (SD SD 2010). The Boscaljons owed about $200,000 dating back to 1993 and 1994. The IRS went to court to sell their residence. At the time of trial the taxpayers were both 74 years old, and living apparently primarily on social security, plus Mrs. Boscalon’s earnings from her $8.75 per hour, 20 hour per week job. Mr. Boscaljon had been diagnosed with cancer, had just completed chemotherapy, and had suffered a heart attack. Despite these facts the IRS brought suit to seize and sell the Boscaljons’ home. So much for a kinder, gentler IRS.

If you have tax liens, tax levies, or other tax problems contact the tax litigation lawyers at Brager Tax Law Group, A P.C.

Taxpayer Advocate Reports Tax Liens as Serious Tax Problem

January 20, 2010,

The Internal Revenue’s (IRS ) tax lien filing polices were in the Taxpayer Advocate’s 2009 Report to Congress listed as the second most serious tax problem facing taxpayers today. This is not a big surprise to those tax lawyers who deal with IRS tax collection problems on a regular basis. I often tell clients that the most difficult objective is to try and get the IRS to release a tax lien prior to making full payment of a delinquent tax liability.

The Taxpayer Advocate’s Report details how the IRS files tax liens without regard to whether or not the taxpayer has assets, and despite the fact that in many instances the filing of a tax lien does not protect the IRS, and only exacerbates the taxpayer’s inability to pay. The Report also points out that the Internal Revenue Manual puts obstacles in the path of their employees who decide not to file a tax lien-- requiring managerial approval, and documentation of any decision not to file a tax lien.

One would only hope that the IRS tax Collection Division takes serious note of the criticisms by the Taxpayer Advocate, and that it not continue to file tax liens as method of punishing taxpayers; however, the IRS responses to the Report make clear that Congressional action will be necessary for any significant tax lien relief.

Taxpayers with tax problems must therefore continue to explore other avenues of relief including offers in compromise, installment payment agreements, audit reconsideration, and bankruptcy to resolve their tax problems.

If you have tax problems call the tax lawyers at Brager Tax Law Group, Inc. for a consultation.

New Foreign Bank Account Report (FBAR) FAQs for Tax Amnesty Expected Shortly

June 10, 2009,

In conversations with the IRS Foreign Bank Account Report (FBAR) hotline, I have been told that the IRS plans on issuing a second FBAR FAQ to supplement the first FBAR FAQ which was issued by the IRS only last month. As readers of this blog know, the first FBAR FAQ was issued to answer questions required the IRS Tax Amnesty program for unreported offshore financial accounts. Once the new FBAR FAQ has been issued by the IRS I will be posting a link to it here on our blog.

If you have an offshore tax problem contact the tax controversy lawyers at Brager Tax Law Group, A P.C. to have a consultation which will be covered by the attorney client privilege.

IRS Seeks to Proceed in Robert Allen Stanford Collection Due Process (CDP) Hearing

March 23, 2009,

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Earlier this year Robert Allen Stanford became infamous when he was accused by the Securities and Exchange Commission (SEC) of engaging in a gigantic fraud. It turns out that Robert Allen Stanford also has massive tax problems. According to a Motion to Intervene filed by the Internal Revenue Service (IRS) in the SEC matter, Stanford and his wife Susan Stanford owe the IRS over $226, 000,000 for the 1999 through 2003 tax years. In addition they may owe additional taxes for other years. The IRS has already filed tax liens against the Stanfords for 2002 and 2003, however, the Stanfords' filed a petition in the United States Tax Court (Tax Court) to dispute the amount of the tax owed. The Stanfords’ petition to the Tax Court for 2002 and 2003 was an appeal from a collection due process (CDP) hearing. The federal tax liens, are fully effective, however, upon filing by the IRS, and if the Stanfords had a prior opportunity to dispute the amount of the tax due then they would not be entitled to another chance due so in the CDP hearing. The entire tax lien and tax levy process was slowed when the District Court in the SEC case issued a general order barring creditors from proceeding with claims against the Stanfords. The IRS motion seeks to allow it to move forward with tax litigation and collection against the Stanfords.

If you have tax liens, or tax levies please call the tax controversy lawyers at Brager Tax Law Group, A P.C.