I was hoping for suggestions for a course of action.
1. Client owes $72K (years 2001 – 2007).
2. The SOL on collections expires April 2019.
3. Client received IRS notice LT16, account has been assigned for enforcement action
4. Client also has unfiled returns for 2015-2017, with an estimated cumulative balance due of an additional $78K
The client is concerned the IRS will garnish wages or levy their bank account before the SOL expires. Any request to delay collections would appear to be counterproductive as it would extend the CSED. Any ideas would be appreciated.
Bryan, try and make the client CNC. CNC does not extend the statute. So do the 433-A analysis. if they are positive see if there are some financial moves you can make to get them into CNC – like health insurance, etc. If you go through the Offer program in the members area we do a case study like this. I would try and get the client cnc and run out the statute. Worse case is set up an installment agreement. The statute will toll while it is pending but will start running again once the agreement is approved.