July 2, 2021 at 3:26 am #45293
I’m working a case with Joseph Kennedy, offer specialist who knows everything. Today he told met that the IRS is telling their offer specialists to ignore using 2020 in the calculation of the averages if it is unusually low. That will raise the averages for purposes of the RCP and make it worse for the taxpayer. This policy was just released yesterday.July 2, 2021 at 11:37 am #45294Eric GreenKeymaster
Terrence, first of all Joe Kennedy is as old as the hills and has never accepted an Offer in his life. Its an automatic appeal from him.
That said that is not a new policy but has always been the policy – if the decline is temporary it should not be used for calculating the Offer. This does make sense – why agree to settle a debt just because the taxpayer is having an off year.
If however you can point to the year being the new normal because of a permanent change, then it should be considered.
EricJuly 4, 2021 at 11:40 pm #45405
I wondered why his deadlines for docs were so short. Sometimes as short as a week. My client was screaming at me for being unprofessional because of the short deadlines.
Can he legitimately set such such deadlines? The Service had the file for over a year.July 17, 2021 at 12:27 am #45436
Well, Joe approved my offer! He was very cordial and taught me more than a few things He was always accessible. We got along just fine. Must have been my charming personality! I’m older than he is so what does that make me? Older than dirt?July 17, 2021 at 12:27 am #45437
Well, Joe approved my offer! He was very cordial and taught me more than a few things He was always accessible. We got along just fine. Must have been my charming personality! I’m older than he is so what does that make me? Older than dirt?July 17, 2021 at 11:34 am #45438Eric GreenKeymaster
Terrence, its great news on the Offer – I guess there is a first time for everything. It must have been your sparkling personality.
You know my offers cases that I joke about – the out of business LLC the IRS claimed at COIC was really worth $7 million because there must be “intellectual property” that the owner knows? Those f’d up cases are all Joe Kennedy.
I am glad this worked out well for you and the client.
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