Forum Replies Created
I would not show it but explain in the cover letter that the taxpayer is receiving unemployment which ends in September. You don’t want to ignore it and look like you are being sneaky but I don’t want it listed as if its something we believe they should factor in.
Jeremy I do not, and I would not be comfortable with it unless there is some precedent or guidance that says its okay
Here are my responses:
1) Yes, I always feel you should expect they will examine everything given they usually do
2) 2020 before its filed is weird
3) Some agents like to surprise, others didn’t think of it during the call, and some are told afterward by their supervisor to add it.
4) You should get a 2848 from them
5) They need to send an audit notice for those and unless you have a 2848 on file they wont send it to you but to the taxpayers directly
6) Gather invoices/receipts from vendors if you can, reconstruct the rest
7) I am not a quickbooks expert so I will defer to the group but they want the electronic back-up so they can see the adjusting entries and audit trail. Key is to not give them more info than that covered by the audit period
1. Correct – the tax liability has to e assessed first
2. once the bill comes call ACS and arrange a streamlined agreement over the CSED (new procedure is $250,000 or less over the CSED through ACS)
3. Correct, only reasonable cause is available
Terry if you look the IRS usually does not allow late elections where it impacts other tax returns. The 1120s are wrong and his 1040s are all going to need to be amended. You can try but I don’t suspect the IRS will allow itJuly 17, 2021 at 11:34 am in reply to: IRS ignoring 2020 if it’s lower than an average year #45438
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.
No it should not impact his OfferJuly 2, 2021 at 11:37 am in reply to: IRS ignoring 2020 if it’s lower than an average year #45294
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.
I would request a return transcript, and account transcript and wage and earning reports
You can but honestly I dont think its necessary
John, I believe the tracking showing you mailed it before they processed the original or contacted you is sufficient, and honestly about the best you can do these days.
Gary, I think you pitch this as look, you need to first get into compliance, so the books need to get done and then the tax returns get done. Once you do that, now you can move onto resolution.
For those that balk my sort of standard line is that they can do their bookkeeping. Get you a P&L and they can save the money. They wont like that either but its technically their problem. For some reason clients like to think they met you so now its somehow your issue. It isn’t.
Tom, yes they should be filed before the 12153. Now if they are not you can always get them done and file them before the hearing notice comes out from appeals, but if the appeals officer gets assigned the case and does not see the returns on file they may just kill it. So if you really need to, file the 12153 and then hurry up and get the 18 and 19 returns done so they are filed. Also make sure he made his 2020 estimates so he is in compliance.
Gary there is an enterprise version you can put on a server.
Steven, he has to open a bank account and deposit his earnings in and then cut checks for the expenses. The way it is now they would refuse to allow him the expenses. I understand he is concerned about levys so I would have him set up the account, call ACS and request a 45 day hold and get started. You can always file the OIC with one statement and later they will request more when it gets worked.