Reply To: TIME SENSITIVE: 941 Case – Appeals Conference Tomorrow (4/3)

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#13601
Eric Green
Keymaster

1. File 433-B and request CNC for the business tomorrow at Appeals hearing as collection alternative, and give the penalty abatement a shot (and hope for the best). I though the business was closed based on your fact pattern. If it closed file a final 433-B indicating it is closed and CNC status should be a n o brainer.

2. Sell off business assets, designate payments to IRS toward TFRP. You cannot designate the payments from the company – because of the liens they are not considered voluntary. The money will be taken at the closing by the IRS and applied in its own best interest.

I am assuming we would still have to do a 14135 to sell the assets under those circumstances, correct? Yes

In any case, the proceeds from that sale would clear up all of the TFRP, but what happens then with the rest of the penalties, interest, etc.? It will not clear the TFRP but pay off all penalties, interest and some of the underlying tax. The balance remaining will be TFRP and the taxpayer can then do an OIC.

3. What alternatives if they don’t give us the CNC status? (shudder) They will if it is no longer operating. Will want to confirm the bank accounts are closed and the game plan for the assets (listing of the properties, auction for the equipment, etc)