Archive for the ‘Offer in Compromise’ Category

Offer In Compromise Multiple Submissions

Posted by John Ellsworth, Esq December 2nd, 2011

Did you know there’s no limit to the number of times you can submit an Offer In Compromise for consideration by the IRS? This fact can lead to some creative lawyering by your tax lawyer. Here’s how that might happen. The Internal Revenue Manual at 5.8.2.4.1 provides examples of “hardship” and “equity” cases in almost [...]

The Notice of Deficiency–What Comes Next?

Posted by John Ellsworth, Esq September 6th, 2011

The Notice of Deficiency–What Comes Next? At the end of the audit the IRS will typically send you what’s called a Notice of Deficiency or Statutory Notice. This is a notice from the IRS that gives you 90 days in which to file your case in Tax Court, or do nothing, or agree to the [...]

How to Keep Your New Wife Off Your “Offer in Compramise”

Posted by John Ellsworth, Esq June 3rd, 2011

Let me start by giving you some general comments. Assume you have undergone an income tax audit prior to marriage and you wind up owing IRS tax. If the liability is joint and both parties wish to make the offer in compromise, both names must be shown. If the taxpayer is singly liable for a [...]

Offer In Compromise Valuation Issues

Posted by John Ellsworth, Esq July 13th, 2010

Offer In Compromise Valuation Issues One of the places the tax lawyer can really help the taxpayer in making a good Offer In Compromise is in the valuation of assets in order to establish the proper offer amount. This is because the IRS rules require that the taxpayer offer to settle his or her debt [...]