Preventing an NFTL

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    Bob Jablonsky

    I have a Taxpayer that’s come to me. The TP and spouse owe around $240k to the IRS due to unexpected Capital Gains on their 2017 return. They previously worked with a national firm that got them a 120 day extension to full pay. It is now 117 days in. They are not able to full pay but can make a $50k payment immediately, $50k within a week, $90k within 6 weeks, and then would like to put the remaining $50k on an installment agreement with auto debit to avoid the lien. They are partners with commercial real estate and feel that having an NFTL will crush their ability to earn income (and it would harm their ability to pay the IRS as well). Just as an fyi on notices, the TP had received a CP504 but did not yet receive a Letter 11.

    When speaking to the ACS rep today, she conferred with a manager and told me that they could give no extension of time to pursue collections, even with the payments. However, she was unable to tell me if collections would include an NFTL filing. I have asked for a manager’s conference and expect a callback within 24 hours. The goal would be to get a hold on collections with a CAP hearing to buy them some time.

    However, I’m fairly new at this and don’t want to mishandle the case. Does anyone have thoughts on the best way to approach this to get the TP time to resolve the debt how to best address it with the manager. Thanks.

    Carl Wessels

    Eric and others may correct me, but on a MUCH smaller case – just sending the ‘ACS rep’ a copy of the Offer in Compromise I threw together – got the ACS department to shut up for — well since last November now. Obviously they will say no to your OIC – but in 6 months y’all will have it mostly paid.

    Well TP’s never actually pay like they promise, so….

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