IRS collection options
8/30/07
4/4/09
- Collection Options:
- extension up to 120 days to pay taxes in full
- currently not collectible (hardship) status – delay collection until financial condition improves
- installment payments
- bankruptcy
- expiration of Statute of limitations
- offer in compromise – settle for less than full payment
- See also: collection standards
- financial Information forms
- collection due process hearing right
- IRS Taxpayer Advocate Service (TAS)
- IRS Form 911 – Request for Taxpayer Advocate Service Assistance/ hardship relief
- Low Income Taxpayer Clinic (LITC)
- determining the correct tax
- audits / recordkeeping
- IRS correspondence audits
- notice of deficiency
- Tax Court
- what if you haven't filed returns
- trust fund recovery penalty
- what if you can't pay your taxes
- what if my spouse owes taxes but I don't
- can I really settle for pennies on the dollar ?
- innocent spouse relief
- injured spouse relief
- tax liens & levies
- subordination of lien
- can the IRS take my house
- abatement of penalties
- discharge of property from lien
- subordination of IRS lien, e.g., to refinancing
- bankruptcy doesn't remove a tax lien even after the tax is discharged
- trust fund recovery (responsible person) penalty
- private party (non-IRS) debt collectors
- tenancy by the entirety protections US v. Craft
Determining How to Respond to IRS Collection
There are four steps in deciding how best to deal wi1h your tax problem:
Determining the extent of your tax problem.
This involves reviewing your tax returns, or preparing and filing returns if not yet filed, reviewing IRS audit reports, collection notices, transcripts and correspondence, and related items such as bankruptcy filings, to determine the amount of unpaid tax, penalties and interest.
Determining the "procedural posture" of your matter.
Has the IRS:
- requested returns be filed ?
- notified you of an audit ?
- proposed an assessment ?
- sent a notice of deficiency, and if so whether you responded by filing a Tax Court petition ?
- requested contact to discuss a balance ?
- filed a tax lien or issued a garnishment or levy, and if so, do you qualify for a collection due process appeal, etc. ?
Do you agree that the correct amount of tax was assessed ? If not, can your contest and correct the amount due, and do you have the documentation to do so ?
Do you have reasonable cause to request abatement of penalties ?
Is any immediate action is required, e.g., terminating a wage garnishment, or requesting subordination of a tax lien allow you to refinance your residence loan to achieve a lower interest rate or lower your monthly payments ? Or a discharge of property from the lien to allow you to sell your residence ?
When were the taxes assessed to determine when the statute of limitations on collections expires (taking into account any voluntary extension, or offer in compromise or bankruptcy), and whether you can discharge some all of your taxes in bankruptcy ?
Reviewing your financial information (form 433-A, and if applicable, 433-B) and other considerations.
What is your ability to pay your tax, make payments or qualify for currently not collectible status, file an offer in compromise, etc.
Developing a plan to deal with your tax matter based on the above and available collection options, including:
Extension of time
Extension of time to pay taxes in full for up to 120 days.
Currently not collectible (hardship) status
If your "reasonable and necessary living expenses" (as determined by the IRS) exceeds your cash flow, you will be placed in "uncollectible" status. Currently not collectible status does NOT resolve your tax problem, and only delays collection until your financial condition improves, or the statute of limitations on collections, below) expires.
Installment payments
Installment payments payable monthly equal to the amount by which your money available to live on in exceeds your "reasonable and necessary" living expenses. This may pay the taxes in full or the IRS may enter into a partial payment agreement.
Bankruptcy
Bankruptcy may discharge certain income taxes (not employment, trust fund or sales tax) where the return was filed, and the due date (typically April 15 of the following year) is more than 3 years before the filing of the bankruptcy petition.
Expiration of Statute of limitations
The expiration of Statute of limitations results in the taxes becoming uncollectible.
Offer in compromise
The IRS may accept an offer in compromise and settle for less than full payment.
See also:
- IRS collection standards The IRS will typically "request" that you provide it with financial information to determine your ability to pay outstanding taxes
- innocent spouse relief
- enforced collection
