Affordable Immediate Tax Levies Releases – Ft.Lauderdale, Miami – Broward, Dade County

Fresh Start Tax
 
Give us your complete and accurate financial statement and we will usually get your tax levy released immediately.
We are comprised of tax attorneys, certified public accountants, and former IRS agents. Our former IRS agents have worked out of the local South Florida IRS offices for a combined 60 years.
They have worked as IRS agents, IRS auditors, IRS revenue officers,  IRS appeals agents, as well as IRS teaching instructors right  here in South Florida.
As a result of their years of tax experience they know all the tax protocols, all the IRS settlement formulas and all the IRS settlement strategies to get immediate tax levy releases.
Not only can we get affordable immediate tax levy releases we can also settle your IRS case at the same time.
Before the Internal Revenue Service will release any tax levy they will require a financial statement and want all tax returns filed and up to date.
That financial statement will need to be on form 433F.
You can find that financial statement on our website.
That financial statement will need to be complete and accurate. It will need to include all documentation including the last 3 to 6 months bank statements and all income and expenses as well as the last pay stubs. Your statement must be completely verified.
Once IRS completely reviews the financial statement, the IRS will then close the case by one of three closing methods.
IRS will either place the case into:

  • currently noncollectable,
  • IRS will insist on a monthly or current installment payment or,
  • they may suggest the filing of an offer in compromise.

 
Once IRS determines the closing method and reviews your financial statement they will immediately send a levy release to the bank or to your employer and close your case off the enforcement computer that very day.
Once the Internal Revenue Service receives that financial statement that process will usually take no more than 24 hours. It is critical that IRS received that financial statement immediately. Get us your financial statement and we will get you your levy release.
 
What is a Tax Levy to you have received

A levy is a legal seizure of your property to satisfy a tax debt.
Levies are different from liens.There are bank levies and wage levies.
A lien is a claim used as security for the tax debt, while a levy actually takes the property to satisfy the tax debt.
If you do not pay your taxes or make arrangements to settle your debt  the IRS may seize and sell any type of real or personal property that you own or have an interest in.
For instance,

  • IRS could seize and sell property that you hold such as your car, boat, or house or
  • IRS could levy property that is yours but is held by someone else such as your wages, retirement accounts, dividends, bank accounts, licenses, rental income, accounts receivables, the cash loan value of your life insurance, or commissions.

 
IRS usually levy only after these three requirements are met:
1.  They assessed the tax and sent you a Notice and Demand for Payment;
2.  You neglected or refused to pay the tax; and
3.  The IRS sent you a Final Notice of Intent to Levy and Notice of Your Right to A Hearing (levy notice) at least 30 days before the levy.
The IRS may give you this notice in person, leave it at your home or your usual place of business, or send it to your last known address by certified or registered mail, return receipt requested.
If you have very received a bank levy there is a 21 day freeze put on the money. The bank will hold the money for a 21 day period therefore you have 21 day period to get the release from the IRS.
Employers generally have at least one full pay period after receiving a Form 668-W, Notice of Levy on Wages, Salary and Other Income before they are required to send any funds from their employee’s wages. Encourage your employees that have a levy placed on their wages to contact the IRS as soon as possible to discuss a release of levy and resolution of their tax liability.
If IRS issues you a Release
A levy release does not mean you are exempt from paying the balance.
The IRS will work with you to establish payment plans or take other steps to help you pay off the balance.
To help ensure quick action, please have the fax number available for the bank or employer office that is processing the levy.
You may ask an IRS manager to review your case, or you may request a Collection Due Process hearing with the Office of Appeals by filing a request for a Collection Due Process hearing with the IRS office listed on your notice. You must file your request within 30 days of the date on your notice.
 
Some of the issues you may discuss include:
 

  •     You paid all you owed before we sent the levy notice,
  •     The IRS assessed the tax and sent the levy notice when you were in bankruptcy, and subject to the automatic stay during bankruptcy,
  •     The IRS made a procedural error in an assessment,
  •     The time to collect the tax (called the statute of limitations) expired before we sent the levy notice,
  •     You did not have an opportunity to dispute the assessed liability,
  •     You wish to discuss the collection options, or
  •     You wish to make a spousal defense.

At the conclusion of your hearing, the Office of Appeals will issue a determination. You will have 30 days after the determination date to bring a suit to contest the determination. Refer to Publication 1660 (PDF), for more information.
If the matter is still unresolved, the manager can explain your rights to appeal to the Office of Appeals.

Affordable Immediate Tax Levies Releases – Ft.Lauderdale, Miami – Broward, Dade County

 

FBAR Penalty Negotiation Defense – Affordable Attorneys, Lawyers, Former IRS

Fresh Start Tax
Getting Rid of FBAR Penalties
Contact us today for free initial tax consultation. We are comprised of tax attorneys, tax lawyers, and former IRS agents who have over 60 years of working directly for the Internal Revenue Service in the local, district, and regional tax offices of the Internal Revenue Service.
We are A+ rated by the Better Business Bureau and have been in private practice since 1982.
The IRS has been delegated authority to assess FBAR civil penalties.
There are civil penalties for negligence, pattern of negligence, non-willful, and willful violations. And believe it or not some of the budget is made up for Internal Revenue Service comes from penalties and interest from the Fbar. Fbar is becoming very popular in IRS circles.
Over the last three filing seasons the IRS has collected over $5.5 billion in Fbar alone and it is not going away. The threat of criminal prosecution is scaring many people into the filing of their FBAR reports and amending their tax returns as they should.
It is important for taxpayers to understand that they should find IRS before IRS finds them.
Auditor Procedures
Whenever there is an FBAR violation, the examiner will either issue the FBAR warning letter, Letter 3800, or determine a penalty.
Reason for FBAR Penalties
Penalties should be asserted only to promote compliance with the FBAR reporting and record keeping requirements.
In exercising their discretion, examiners should consider whether the issuance of a warning letter and the securing of delinquent FBARs, rather than the assertion of a penalty, will achieve the desired result of improving compliance in the future.
Civil Penalties for FBAR
FBAR civil penalties have varying upper limits, but no floor.
The tax examiner has great discretion in determining the amount of the penalty, if any. The tax examiner discretion is necessary because the total amount of penalties that can be applied under the statute can greatly exceed an amount that would be appropriate in view of the violation.
Tax Examiners are expected to exercise discretion, taking into account the facts and circumstances of each case, in determining whether penalties should be asserted and the total amount of penalties to be asserted.
Because FBAR penalties do not have a set amount, IRS has developed penalty mitigation guidelines to assist examiners in the exercise of their discretion in applying these penalties. this is why it is in the best interest of taxpayers to use season and experienced tax professionals to handle to Fbar penalty negotiation defenses. Believe me when I tell you as a former IRS agent this experience will save you great volumes of money
The mitigation guidelines are only intended as an aid for the examiner in determining an appropriate penalty amount.
The tax examiner must still consider whether a warning letter or a penalty amount that is less than what would be called for under the mitigation guidelines would be more appropriate given the facts and circumstances of a particular case.
An Example of this
For example, if an individual failed to report the existence of five small foreign accounts with a combined balance of $20,000 for all five accounts but the income from each account was properly reported and the taxpayer made no effort to conceal the existence of the account, it may be more appropriate to issue a warning letter rather than assert penalties under the mitigation guidelines.
FBAR penalties are determined per account, not per unfiled FBAR, for each person required to file. Penalties apply for each year of each violation.
As noted above, however, tax examiners are expected to exercise discretion, taking into account the facts and circumstances of each case, in determining whether penalties should be asserted and the total amount of penalties to be asserted.
Multiple FBAR Penalties
There may be multiple FBAR civil penalty assessments arising from one account.
FBAR civil penalties can apply to each person with a financial interest in, or signature or other authority over, the foreign financial account.
Thus there may be multiple penalty assessments if there is more than one account owner or if a person other than the account owner has signature or other authority over the foreign account.
Each person can be liable for the full amount of the penalty.
Some taxpayers who are dual citizens of the U.S. and a foreign country or who are merely U.S. citizens living and working abroad, may have failed to timely file their FBAR reports.
Good News about FBAR Penalties
The good news is that there is a reasonable case exception under the FBAR Statute that that may eliminate the FBAR penalty altogether..
The authority for the “reasonable cause” exception is found in the IRS Manual IRM 4.26.16.4.3.1 (07-01-2008). See IRS.gov for more on this. If you are going to do this by yourself you would do yourself well by researching are doing some due diligence on this issue.
This IRM approves of the reasonable cause guidance provided under 26 C.F.R. § 1.6664, Reasonable Cause and Good Faith Exception to the § 6662 penalties. IR-2012-65, June 26, 2012 offers a new procedure that will go into effect September 1, 2012, that speak to the reasonable cause exception to the FBAR penalty.
Whether a failure to file or failure to pay is due to “reasonable cause” is based on a consideration of the facts and circumstances.
Reasonable cause relief is generally granted by the IRS when you demonstrate that you exercised ordinary business care and prudence in meeting your tax obligations but nevertheless failed to meet them. In determining whether you exercised ordinary business care and prudence.
The IRS will consider all available information, including:
 

  • The reasons given for not meeting your tax obligations;
  • Your compliance history;
  • The length of time between your failure to meet your tax obligations and your subsequent compliance; and
  • Circumstances beyond your control.

 
FBAR reasonable cause may be established if you show that you were not aware of specific obligations to file returns or pay taxes, depending on the facts and circumstances.
Among the facts and circumstances that will be considered are:
 

  • Your education level;
  • Whether you have previously been subject to the FBAR Reporting tax;
  • Whether you have been penalized before, your history plays a very important role.
  • Whether there were recent changes in the tax forms or law that you could not reasonably be expected to know; and
  • The level of complexity of a tax or compliance issue.
  • Reliance upon the advice of a professional tax advisor who was informed of the existence of the foreign financial account.
  • Evidence that the foreign account was established for a legitimate purpose.
  • Evidence that there was no effort to intentionally conceal the reporting of income or assets.
  • Evidence that there was no tax deficiency related to the unreported account.

 
There may be other factors in addition to those listed that may weigh in favor of a determination that the failure to file was due to reasonable cause. Is the job of the tax professional that you have retained to help with these other factors.
Ignorance of the law, if reasonable along with a good faith effort to comply with the law if you could not reasonable be expected to know of the FBAR requirement.
 
No single factor will determine reasonable cause. It is a facts and circumstances test. As a former IRS agent I can tell you, look at the whole body of the case.
 
FBAR Penalties – IRS Tax Examiner Discretion
The examiner may determine that the facts and circumstances of a particular case do not justify asserting a penalty. If there was an FBAR violation but the examiner determines that a penalty is not appropriate, the examiner should issue the FBAR warning letter, Letter 3800.
When a penalty is appropriate, IRS has established penalty mitigation guidelines to aid the examiner in applying penalties in a uniform manner.The examiner may determine that a penalty under these guidelines is not appropriate or that a lesser penalty amount than the guidelines would otherwise provide is appropriate or that the penalty should be increased (up to the statutory maximum).
The examiner must make such a determination with the written approval of the examiner’s manager and document the decision in the work papers.
Factors to consider when applying examiner discretion may include, but are not limited to, the following:
Whether compliance objectives would be achieved by issuance of a warning letter;
Whether the person who committed the violation had been previously issued a warning letter or has been assessed the FBAR penalty;
The nature of the violation and the amounts involved; and,
The cooperation of the taxpayer during the examination.
Given the magnitude of the maximum penalties permitted for each violation, the assertion of multiple penalties and the assertion of separate penalties for multiple violations with respect to a single FBAR form, will be considered.

FBAR Penalty Negotiation Defense – Affordable Attorneys, Lawyers Former IRS

IRS Tax Debt Reduced – New Program Offered by IRS – Affordable – Miami, Ft.Lauderdale, Palm Beaches

Fresh Start Tax
The Internal Revenue Service is now accepting more offers in compromise than ever before.
Yes , the IRS is willing to finally reduce tax debt. The latest report issued by the federal government has shown that the Internal Revenue Service has accepted 38% of all submitted offers in compromise submitted and that is up from 28% from the prior year.
Last year 58,000 offers in compromise were filed by taxpayers and the Commissioner of the Internal Revenue Service had instructed its staff of agents to do a better job of accepting settlements and offers an apparently they got the word.
Now is the time to file an offer in compromise to reduce your IRS tax debt.
Before everyone goes running out to file to reduce there there tax debt,there are some important things to understand.
You can find a pre-qualifier tool on our site and I would advise all taxpayers and potential clients to walk through the program to make sure they are qualified before they submit offers in compromise to reduce their tax debt.
We are available for free initial consultation and we will be happy to walk you through the program and make sure you are a qualified person to settle your tax debt.
Please find below the new program offered by the Internal Revenue Service for the settlement of an IRS tax debt reduction.
 
More Flexible Offer-in-Compromise Terms Help Taxpayers Make a Fresh Start
 
The IRS has expanded its “Fresh Start” initiative by offering more flexible terms to its Offer-in-Compromise Program.
These newest rules enable some financially distressed taxpayers to clear up their tax problems even quicker.
An offer-in-compromise (OIC) is an agreement between a taxpayer and the IRS that settles the taxpayer’s tax liabilities for less than the full amount owed.
An OIC is generally not accepted if the IRS believes the liability can be paid in full as a lump sum or through a payment agreement.
The IRS looks at the taxpayer’s income and assets to determine the reasonable collection potential.
This expansion of the “Fresh Start” initiative focuses on the financial analysis used to determine which taxpayers qualify for an OIC.
Here are the OIC changes:
Revising the calculation for a taxpayer’s future income The IRS will now look at only one year (instead of four years) of future income for offers paid in five or fewer months; and two years (instead of five years) of future income for offers paid in six to 24 months.
All OICs must be paid in full within 24 months of the date the offer is accepted.
Allowing taxpayers to repay their student loans Minimum payments on student loans guaranteed by the federal government will be allowed for the taxpayer’s post-high school education. Proof of payment must be provided.
Allowing taxpayers to pay state and local delinquent taxes When a taxpayer owes delinquent federal and state or local taxes, and does not have the ability to fully pay the liabilities, monthly payments to state taxing authorities may be allowed in certain circumstances.
Expanding the Allowable Living Expense allowance Standard allowances incorporate average expenses for basic necessities for citizens in similar geographic areas. These standards are used when evaluating installment agreement and offer-in-compromise requests.
The National Standard miscellaneous allowance has been expanded. Taxpayers can use the allowance to cover expenses such as credit card payments and bank fees and charges.
It is important to know that any taxpayer who wants to reduce their tax debt via the offer in compromise will need to fill out form 433 OIC which is the offer in compromise form. You can find that form on our website.
If you’d like us to review that form it would be a good idea for you to have that form completed and have it available for us to review it and go over with you. Please keep in mind that our staff has over 60 years of combined IRS experienced in the local South Florida IRS offices.
We can give you a comprehensive review of your case and give you various tax options and solutions to reduce your IRS tax debt. Call us today for free initial tax consultation

IRS Tax Debt Reduced – New Program Offered by IRS – Affordable – Miami, Ft.Lauderdale, Palm Beaches

Payroll Tax Audits – Ft.Lauderdale, Miami, Palm Beach – Affordable Former IRS Agents

Fresh Start Tax
We are comprised of tax attorneys, certified public accountants, and former IRS agents, managers and tax instructors.
We are A+ rated by the Better Business Bureau and have been in private practice right here in South Florida since 1982.
We have over 206 years of professional tax experience. We have over 60 years of working in the local, district, and regional tax offices of the Internal Revenue Service. We are tax experts for payroll tax audits
If you are undergoing a Payroll or Employment Tax Audit you better hire a professional tax firm because this is not a situation you want to lose.
Being a Former IRS Agent you should know these are dangerous tax audits.
Make sure you get tax representation for this type of tax audit.I am not telling you this to scare you but there is a huge downside to these tax audits. Not only can the business wind up owing money but the individual can wind up with a personal tax assessment as well.
Once the IRS sets up a tax deficiency for payroll or employment taxes the IRS has the right to file federal tax liens and control the amount of money you can make as a result of owing back payroll taxes. IRS will control your individual and business spending.
Do not let the IRS bully you during a payroll or employment tax audit!
Call Fresh Start Tax LLC 1-866-700-1040, home of former IRS agents.
Payroll Tax Audits
IRS does not take lightly the business owing payroll taxes because this is really not a tax but monies held on trust for the IRS and the FEDS.
The process works like this:
The IRS will pull a case from the CADE 2 computer for a tax audit and then notify the taxpayer / business of a payroll or employment tax audit.
The Agent will schedule a date for a meting usually at your place of business. It is better to have the audit at your representatives office.
The IRS can and will ask for back records generally for the past three years.
The IRS Agent when finished, will issue a tax report in which you have the right to appeal. If the IRS feels there was a criminal element involved they have the right to refer the case to criminal division.
Most cases simply end up with a tax deficiency, IRS will then send you a bill and the IRS will be expecting full payment.
WHAT IRS LOOKS FOR DURING THE TAX AUDIT.
The IRS agent will be targeting employees to see whether or not they are true employees or self employed agents.
There are common law tests to determine which classification a employee may fall under. This battery of questions you will find below will help the IRS agent determine in which category a employee may fall.
It is very important to remember there is not one factor used to make this determination but where the preponderance of evidence falls. If the IRS determines these workers are actually employees you will have problems because the IRS wants all of the back taxes plus penalties and interest.
Common law test for payroll tax audits or employment tax audits use by the IRS agent:
What was the:
Level of instruction. If the company directs when, where, and how work is done, this control indicates a possible employment relationship. The IRS will look for training manuals and policies the companies use. The IRS can use former employees to answer these questions as well.
Amount of training. Requesting workers to undergo company-provided training suggests an employment relationship since the company is directing the methods by which work is accomplished. The more training, the Service takes the position that the individual is an employer.
Degree of business integration. Workers whose services are integrated into business operations or significantly affect business success are likely to be considered employees. Those whose services are for the production of income to a great level are scrutinized more closely.
Extent of personal services. Companies that insist on a particular person performing the work assert a degree of control that suggests an employment relationship. In contrast, independent contractors typically are free to assign work to anyone. Once again this goes to control.
Control of assistants. If a company hires, supervises, and pays a worker’s assistant, this control indicates a possible employment relationship. If the worker retains control over hiring, supervising, and paying helpers, this arrangement suggests an independent contractor relationship. There are exceptions to this.
Continuity of relationship. A continuous relationship between a company and a worker indicates a possible employment relationship. However, an independent contractor arrangement can involve an ongoing relationship for multiple, sequential projects. Also, does the individual have another job or is this the sole source of their income. Is their license available to everyone?
Flexibility of schedule. People whose hours or days of work are dictated by a company are apt to qualify as its employees. Does the individual punch a time clock or is the employee free to come and go? Does the person have a key to the facility?
Demands for full-time work. Full-time work gives a company control over most of a person’s time, which supports a finding of an employment relationship. The IRS will look to see if the individual has other W-2 income.
Need for on-site services. Requiring someone to work on company premises—particularly if the work can be performed elsewhere—indicates a possible employment relationship. Are name badges and uniforms required?
Sequence of work. If the company requires work to be performed in specific order or sequence, this control suggests an employment relationship. Does the employee do the same thing every day?
Requirements for reports. If a worker regularly provides written or oral reports on their the status of a project, this arrangement indicates a possible employment relationship. Is there an evaluation given?
Method of payment. Hourly, weekly, or monthly pay schedules are characteristic of employment relationships, unless the payments simply are a convenient way of distributing a lump-sum fee. Payment on commission or project completion is more characteristic of independent contractor relationships. Time clocks tend to look like hourly employees. What does the tax return of the individual look like?
Payment of business or travel expenses. Independent contractors typically bear the cost of travel or business expenses, and most contractors set their fees high enough to cover these costs. Direct reimbursement of travel and other business costs by a company suggests an employment relationship. Does the individual have a company credit card or expense account, how about a possible credit card of the company?
Provision of tools and materials. Workers who perform most of their work using company-provided equipment, tools, and materials are more likely to be considered employees. Work largely done using independently obtained supplies or tools supports an independent contractor finding. The checking of the individual 1040 for a schedule C expense form is a good cross check for the IRS.
Investment in facilities. Independent contractors typically invest in and maintain their own work facilities. In contrast, most employees rely on their employer to provide work facilities. Are there incentive programs for the individuals?
Realization of profit or loss. Workers who receive predetermined earnings and have little chance to realize significant profit or loss through their work generally are employees. Is the individual on a pension system or health insurance?
Work for multiple companies. People who simultaneously provide services for several unrelated companies are likely to qualify as independent contractors. That is why the individual tax returns may be checked.
Availability to public. If a worker regularly makes services available to the general public, this supports an independent contractor determination. Does the individual have other business cards and is their business open to the public? Does the person have other work going on at the same time?
Control over discharge or firing. A company’s right to discharge a worker suggests an employment relationship. In contrast, a company’s ability to terminate or fire the independent contractor relationships generally depends on contract terms. Is there a contract between both parties. does it contain accurate details? You will find below a sample of a contract.
Right of termination. Most employees unilaterally can terminate their work for a company without liability. Independent contractors cannot terminate services without liability, except as allowed under their contracts.
Remember, do not take payroll tax audit lightly. It is best to hire a tax professional. Call us today for a free initial tax consultation.
 

Payroll Tax Audits – Ft.Lauderdale, Miami, Palm Beach – Affordable Former IRS Agents

 

Former IRS Agents, Revenue Officers, Appeals Agents – Miami, Ft.Lauderdale, Palm Beaches – South Florida

Fresh Start Tax

Michael Sullivan
Former IRS Revenue Officer, Tax Consultant

 
Please feel free to contact Mr. Sullivan & Mr Andreacchi if you have any questions. Free consultations are available.  954-492-0088
 
Michael D. Sullivan  had a distinguished career with the Internal Revenue Service for 10 years. As a veteran IRS Revenue Officer / Agent, he served as an Offer in Compromise Tax Specialist and Large Dollar Case Specialist. He also collaborated with the U.S. Attorney’s office in many undercover operations.
Michael received several awards for his work and dedication as a Revenue Officer. During his tenure with the IRS, he was a Certified Tax Instructor who taught out of the Atlanta Regional IRS Training Offices. He also taught out of the local and regional offices of the IRS. Mr. Sullivan trained many of the new IRS Agents.
Michael has been in private practice since 1983. He often consults with corporations and individuals, which involves a wide range of tax issues. Michael has worked many large complex cases for high net worth individuals and large corporations.
Mr. Sullivan is a committed professional with dedicated involvement in the professional tax community as a frequent speaker on the South Florida circuit and also served as an officer and on the Board of the Greater South Florida Tax Council.
Michael has been the program host and moderator for several Internal Revenue Service forums both in the public and professional sectors. Michael is also a member of the National Society of Accountants. Mr. Sullivan is also registered with the Department of Business and Professional Regulation and has an approved class for IRS Collection Matters for Certified Public Accountants and Attorneys. Course # 0012279 expires 11/04/2013.
Michael graduated from St. Thomas University with a B.A. in Pre-Law. He also has attended Knox Theological Seminary. Mr. Sullivan has obtained a Life Time Achievement Award for Little League Baseball and currently sits on the International Board for the Walk to Emmaus. Michael also is a proud member of the Life Work Leadership program.
 

Frank Andreacchi

Former IRS Revenue Agent/Appeal Agent

 
Is employed with Fresh Start Tax LLC.
Frank Andreacchi
He is a Former IRS Revenue Agent, Appeals Officer, Federal Tax Mediator, Gallatin Award form the U.S. Department of the Treasury
With 35 years of employment with the Internal Revenue Service, Francis A. Andreacchi has a vast amount of knowledge and experience. In 1974, he started as an Office Auditor in the Office Audit Division where he examined individual tax returns.
In 1977, he was promoted to Revenue Agent in the Field Audit Division. As a Revenue Agent, he examined high income individuals, large corporations, partnerships and trusts. In the Tax Shelter Audit Program, he specialized in the examination of complex financial transactions.
In 1982, Francis was promoted to Appeals Officer in the Appeals Division where he spent the last 35 years of his career with the IRS. As an Appeals Officer, he conducted conferences to settle cases in which taxpayers have appealed Internal Revenue Service determinations on their tax case or filed a petition in U.S. Tax Court. Francis had the authority to recommend the final disposition of the case from the government’s perspective and to prepare the final settlement.
As an Appeals Officer, he was assigned various income tax cases involving individuals, trusts, partnerships and corporations from the Examination Division. These cases involved omitted income, disallowed expenses and various penalties as substantial understatement of tax, fraud, failure to file and failure to pay. In conjunction with these cases, he had to consider innocent spouse issues raised by one of the spouses.
As an Appeals Officer, he was also assigned various collection cases from the Collection Division. Such cases included offer in compromise, installment agreements and transferor-transferee issues.
Another type of collection case assigned was the application of the Trust Fund Recovery Penalty on individuals in which the corporation did not pay the payroll taxes. In these cases, Francis was required to make a determination whether the taxpayer was the responsible person who willfully failed to pay the employment taxes and the relative litigating hazards of the taxpayer and the Internal Revenue Service.
His span of case assignment from the Collection Division included Collection Due Process for lien and levy actions. In these cases, he had to consider whether these enforcement actions were proper within the facts and circumstances of the case. Francis had to consider all other issues raised by the taxpayer on his unpaid tax liability, such as whether the liability was correct and whether any penalties should be abatement. Francis also had to consider various collection alternatives raised by the taxpayer such as installment agreements, offers in compromise and currently not collectible status.
Francis is also an IRS trained mediator. As an IRS mediator, his responsibility was to attempt to bring the Internal Revenue Service and the taxpayer to an agreement on their dispute through a conference. He was one of the first mediators to successfully mediate an offer in compromise between the IRS and the taxpayer.
Francis received many Performance Awards for his hard work in successfully resolving cases in the Appeals Division. Upon his retirement from the IRS, the United States Department of the Treasury awarded Francis the Albert Gallatin Award for his contribution to the public service.
As an Enrolled Agent, Francis is licensed by the federal government to represent taxpayers before the IRS. His 60 years as an Appeals Officer with the IRS provides him with the unique knowledge and experience to effectively represent the taxpayer before the IRS.
 
Former IRS Agents, Revenue Officers, Appeals Agents – Miami, Ft.Lauderdale, Palm Beaches – South Florida