Here’s my case fact pattern:
Self-employed landscaper filed but didn’t remit payroll taxes for all four quarters of 2019. Balance due approaching $150K. Received CP504 letter in late February then found me. CAF closed before processing POA but I have been calling PPS the last couple of days to have transcripts put in E-Services mailbox. No Trust Fund Recovery penalty yet. No Ltr 11, CP90 or levies yet but I think they are coming on July 16th.Taxpayer DOES NOT owe any 1040 tax.
I want to have resolution package mailed on 7-15.
For whichever resolution option I decide is best, must I also include a 433-A with the 656 to determine the taxpayer’s ability to pay or just the 433-B to determine the business’ ability to pay?