Fresh Start Tax 1-866-700-1040 A National Tax Practice “A” Rated by the Better Business Bureau
If you are having any issue with the IRS, contact us today. We have over 130 years of direct IRS experience and 60 years of actual working experience at the IRS.
Free consultation. End your problem with one phone call.
Fresh Start Tax is one of the premier tax resolution firms in the country. We deal with all types of civil cases including individuals, businesses, non-profits, partnerships and corporations. We have staff that specialize in every facet of IRS representation. We know all the IRS tax strategies because of our extensive IRS working backgrounds. Some of our many specialties include the following:
Immediate Tax Representation
Offers in Compromise/Settlements
Immediate Release of Bank Garnishments or Wage Levies
IRS Notices/Bill of Intent to Levy or Final Notices
Fresh Start Tax 1-866-700-1040 A Professional Tax Firm “A” Rated by the Better Business Bureau
Fresh Start Tax has over 130 years of direct tax experience along with 60 years of being former agents with the IRS. If the IRS has sent a levy on your bank account or has put a freeze on your wages, call us today for immediate tax relief.
How we get an Immediate Release of Wage or Bank Levies:
1. We immediately send a power of attorney to the IRS letting them know we are now your representative. You will never have to speak them.
2. We will make sure your tax returns are filed and current. If they are not filed, we will prepare and file your tax returns.
3. We will secure a required 433-F (IRS financial statement), verify the income and expenses and work out a settlement agreement.
4. Settlement agreements can be in different forms:
a. Hardship. Hardship cases usually go into a 3 year suspended status because of an inability to pay. This is also called currently noncollectable.
b Payment Agreements are agreed upon monthly installment payments to the IRS.
c. Offer in Compromise. A much longer and detailed process of tax settlement. We will discuss in detail with you the merits of each. 5.The IRS will then fax to your payroll department, bank, or third party a Release Of Levy.
Our Company Resume:
Our staff has over 135 years of professional tax representation experience collectively
On staff, Board Certified Tax Attorney’s, Certified Public Accountants, Enrolled Agents,
Fresh Start Tax 954-492-0088 1-866-700-1040 A Local South Florida Professional Tax Firm “A” Rated by the Better Business Bureau
If you owe the IRS any back tax dollars on overdue taxes, call our tax firm today. We are former IRS Agents who worked in the Miami and Ft.Lauderdale IRS offices. We know all the tips and secrets to help get you the tax relief you need. Not only were we agents, but Managers and Instructors as well.
There is no firm in the South Florida area more equipped to handle your IRS issue. Call us today for a free consultation. Fresh Start Tax is one of the premier tax resolution firms in the country. We deal with all types of civil cases including individuals, businesses, non-profits, partnerships and corporations. We have staff that specialize in every facet of IRS representation. We know all the IRS tax strategies because of our extensive IRS working backgrounds. Some of our many specialties include the following:
Immediate Tax Representation
Offers in Compromise/Settlements
Immediate Release of Bank Garnishments or Wage Levies
IRS Notices/Bill of Intent to Levy or Final Notices
Fresh Start Tax 1-866-700-1040 A Professional Tax Firm “A” Rated Company BBB
If the IRS Revenue Officer rejects your payment agreement, take it the IR.
The “Independent Administrative Reviewer” reviews the decision to reject installment agreement requests independent of employees’ and managers’ opinions. The reviewer must exercise independent judgement to determine if rejection of the installment agreement request is appropriate. The reviewer should use problem solving and negotiation techniques and consider the taxpayer’s perspective when working toward case resolution.
In accordance with Internal Revenue Code sections 6159(f) and 7122(e) taxpayers are entitled to independent administrative reviews of rejected requests for installment agreements. Contact employees (including revenue officers) and managers must ensure that all actions relative to this review are documented in case histories, including:
1. the date the case is sent to the independent reviewer;
2. the date the case is received from the independent reviewer; and
3. the date the case is forwarded for second level review (if applicable).
A side note to be aware of: Independent administrative review is not required in cases in which the installment agreement request is not identified as “pending” due to noncompliance with filing requirements. You must be current.
If the IRS is planning to reject a request for an installment agreement they are to notify taxpayers that rejection of the request is being recommended if that is the next planned action, but do not notify taxpayers of actual rejection of the installment agreement request until after independent administrative review.
Managers must review and concur with plans to reject installment agreement requests prior to independent administrative review.
If managers request additional information or action, these should be requested of the taxpayer or gained from the appropriate source, without commenting to the taxpayer regarding approval status of the agreement other than that the request is being considered. In addition to exercising care with regard to conveying rejection of requests, exercise care regarding conveying acceptances. Specifically, though the plan to accept an installment agreement request can be shared, do not convey acceptance if a request requires managerial approval until approval is obtained.
If rejection is the next planned action, the installment agreement case file will be sent to the Independent Administrative Reviewer along with:
Form 12233, “Independent Review PRIOR to Rejection of Request of Installment Agreement” ;
A statement regarding the reason(s) for the proposed rejection. Bear in mind that the basis for the rejection of an installment agreement request could be the subject of an immediate appeal or a future Collection Due Process hearing;
any documentation submitted by the taxpayer in connection with the installment agreement request;
Installment agreements are not considered “pending” if taxpayers are not in compliance with filing requirements (See IRM 5.14.1.4.1), and therefore they do not require Independent Administrative review.
In deciding to uphold or overturn a proposed rejection, reviewers should:
Consider the case as a whole;
Focus on the reasons for the proposed rejection given by the contact employee (or, if appropriate, the reasons for the proposed rejection given by the group manager);
Determine whether the proposed installment agreement would fully pay the liability before the CSED
Review the analysis of the taxpayer’s financial condition to determine whether the payment amount requested by the taxpayer is adequate, given the taxpayer’s ability to pay;
Determine whether the taxpayer is in compliance with the filing requirements
Determine whether positions expressed by the taxpayer were considered in the interview or review process; and
Determine if reasons for rejection provided by the revenue officer or his/her manager should be provided to the taxpayer. Considering that the basis for the rejection can be the subject of an immediate appeal or a future Collection Due Process hearing, there should be very few circumstances when the taxpayer should not be told of the reasons for rejection. The reviewer should ensure that the reasons for rejection are well documented in the file including, as necessary, why a partial payment installment agreement was not appropriate.
The reviewer may:
Recommend that taxpayers be granted installment agreements (of the same amount proposed by taxpayers, or a different amount).
Concur with decisions to reject agreement requests;
Suggest modifications or conditions to agreements;
Request additional documentation from revenue officers or other contact employees; and/or
Request revenue officers or other contact employees gain additional information or documentation from taxpayers.
Reviewers will provide all reasons for concurring (or not concurring) with decisions to reject installment agreement requests in the remarks section of Form 12233, Independent Review Form. Bear in mind that the basis for the rejection of an installment agreement request could be the subject of an immediate appeal or a future Collection Due Process hearing.
Reviewers must sign and record the date that cases were reviewed on the review form. The reviewer’s original signature must be on Form 12233 and any attachment thereto. IAR reviews will be completed and a determination made no later than 15 business days from opening the ICS OI.
If a case is returned to a revenue officer (or other contact employee), the revenue officer or other contact employee will take the actions directed by the reviewer. If reviewers recommend acceptance of agreements, this information should be relayed to taxpayers, and agreements should be processed.
Exception:
If, after reviewing the reviewer’s report a revenue officer still believes rejection is the proper action, the case file will be resubmitted to the reviewer, along with additional information and an explanation that supports rejection of the installment agreement request. If no resolution can be reached, the decision will be elevated to second level management (Territory Manager).
If a decision to reject an installment agreement request is sustained by the Independent Reviewer:
rejection and, except in rare cases, the basis for rejection must be communicated to the taxpayer by issuing Letter 4052 “Rejection of Proposed Installment Agreement” found on the ICS Installment Agreement Template menu;
specific amounts and conditions for acceptance of the agreement request must be provided to the taxpayer when they are informed of the rejection decision, if sufficient information has been provided to make this determination and an installment agreement is an appropriate resolution;
If the taxpayer later proposes an amount less than what previously was communicated to the taxpayer as being acceptable, this proposal will be deemed as an installment agreement request to delay collection, not requiring another independent review, unless there has been a change in the taxpayer’s circumstances. Approval by the group manager is required
taxpayers must be provided the right to appeal decisions to reject installment agreement requests (See IRM 5.14.9.8); and
If the taxpayer requests an appeal, note all applicable information on Form 12233, including the date of issuance of Form 9423 “Collection Appeal Request” to the taxpayer, the date of receipt of completed Form 9423 “Collection Appeal Request” from the taxpayer, and the date the file was forwarded to Appeals.
If levy is the next intended action, then Letter 1058(DO) or 3174P may be issued to taxpayers at the same time that the rejection of pending installment agreements is communicated to taxpayers using the Letter 4052. See IRM 5.11.1.2.2.2 and IRM 5.11.1.2.2.6 regarding the appropriate letter to use. See IRM 5.7.8.3(6) for exceptions to levy being the next intended action.
Note:
No levy may be issued until after 45 days have passed since the communication of rejection of the request for installment agreement to the taxpayer.
In the event a proposed installment agreement is rejected and it is determined that the taxpayer made a good faith revision of the proposal and submitted the revision within 30 days of the date of the rejection, the installment agreement must be considered anew. If the revised submission is not in good faith, the appeal period continues to run from the date of the original rejection.
Independent reviewers will notify referring contact employees or functions through appropriate channels of the outcomes of reviews, so appropriate TC 971s may be input. (See Exhibit 5.14.1–1.)
If taxpayers propose installment agreements as a collection alternative after requesting a Collection Due Process hearing (CDP) and rejection is planned, then the field employee will forward the CDP periods to Appeals under Collection Due Process (See IRM 5.1.9.3). The independent review for CDP periods is accomplished by approval and signing of Form 5402 (Appeals Case Memorandum cover sheet) by the Appeals Team Manager. This is also true if installment agreements are requested while cases are assigned to Appeals for other reasons. If there are periods in the installment agreement request that are not included in the CDP request, these periods will be sent for independent review by Technical Services in accordance with the procedures provided in IRM 5.14.9.7(14).
Fresh Start Tax 1-866-700-1040 Rated “A” by the Better Business Bureau Professional Tax Firm
Do you owe business 941 taxes to the Internal Revenue Service? Get them resolved today 1-866-700-1040. Our company is comprised of Former IRS Agents and Managers who have been processing these cases for 28 years. We also were former Instructors with the IRS.
You can get an In business Trust Fund Express Installment Agreement:
1. In order to qualify, the entire liability including accruals (INTST) must total $25,000 or less when the case is received in inventory.
2. Taxes are fully paid in 24 months, or before the CSED, whichever is earlier.
3. If accounts qualify for IBTF Express agreements:
4. Collection Field function employees must make a field call to view assets and request full payment prior to granting an IBTF Express agreement.
5. No financial statement is required.
6. The IRS will Input bank and receivables information to IRS computer system for possible levy action.
7. A lien determination is required by Collection Field function employees,
8. No Trust Fund Recovery Penalty determination is required; however, the revenue officer must ensure that the Assessment Statute Expiration Date (ASED) is protected.
9. Check IDRS for (and verify with taxpayers) filing and payment compliance. If not in filing compliance, installment agreements may not be granted.
If for any reason rejection of installment agreements is planned, refer for Independent Administrative Review.
Fresh Start Tax is one of the premier tax resolution firms in the country. We deal with all types of civil cases including individuals, businesses, non-profits, partnerships and corporations. We have staff that specialize in every facet of IRS representation. We know all the IRS tax strategies because of our extensive IRS working backgrounds. Some of our many specialties include the following:
Immediate Tax Representation
Offers in Compromise/Settlements
Immediate Release of Bank Garnishments or Wage Levies
IRS Notices/Bill of Intent to Levy or Final Notices
Fresh Start Tax 1-866-700-1040 Let us audit proof your tax returns Former IRS Agents and Managers “A” Rated by BBB
Payoff Amount for the Federal Tax Liens
The full amount of your lien will remain a matter of public record until it is paid in full, including all accruals and additions. However, at any time you may request an updated lien payoff amount to show the remaining balance due by calling the toll-free customer service telephone number at 1-800-913-6050. An IRS employee will issue you a letter with the current amount that must be paid before the Notice of Federal Tax Lien is released.
