Individuals and business entities are eligible for payment plans, known as installment agreements. A taxpayer must be in compliance, i.e., all outstanding returns must be filed and the taxpayer must show evidence of financial hardship. Installment agreements prevent collection division of taxing agencies from seizure of assets, such as levying wages or bank accounts.
Retrieval of records of account, income transcripts, and transcripts of account provide a taxpayer with the information necessary to understand his outstanding tax obligation. Such transcripts also provide assessment information, lien dates, and return received evidence.
Freedom of information act requests can secure a taxpayers entire file. FOIA requests can provide information regarding taxing agencies audit work papers and tax returns.
Negotiate with taxing agency administrators the full discharge or subordination of tax liens.
Litigate tax issues in bankruptcy court in order to avoid the onerous pay to play requirement of Superior Court and Tax Court litigation.
Negotiate tax lien and levy releases through administrative and judicial means.
Litigate in tax court the full equitable and legal remedies for innocent spouses.
So called pennies on the dollars contracts are accepted by the government taxing agencies, but they require a significant amount of information. The Franchise Tax Board requires collateral agreements, or agreements to pay an additional amount if income increases over a five year period. Both the Internal Revenue Service and Franchise Tax Board place successful offer in compromise candidates on a five year probation.
Analyze foreclosure issues for tax implications, such as capital gain or loss and discharge of indebtedness ordinary income calculations.
Review financial institutions information reporting statements for tax analysis of discharge of indetedness income.
The Law Offices of John A. Harbin and John A. Harbin, sole proprietor