Former IRS Agents + IRS Appellate Experts & Expert Tax Defense + Ft.Lauderdale, Miami, Palm Beaches, Boca Raton, Aventura

Fresh Start Tax

We are one of the most affordable and experienced professional tax firms in South Florida in dealing with the Internal Revenue Service.

 

We have over 200 years of professional tax experience and over 100 years of working directly for the Internal Revenue Service and the local, district, and regional offices of the Internal Revenue Service. We worked out of the local South Florida IRS offices.

Our former IRS agents worked as managers and supervisors in the IRS tax audit division and we know every single way imaginable way to provide you the best possible tax defense if you are going through a IRS tax audit.

If you have received a letter from the Internal Revenue Service stating that you are going through an IRS tax audit, contact us today and we will walk you through the process of what to expect and how to prepare the best tax defense.

If you wish to appeal the findings of the local IRS agent, we can provide the best possible appellate tax defense for going forward.

Call us today for a free initial tax consultation and understand why we are considered the best IRS tax audit help the fence in South Florida.

Many people ask us how IRS determines their cases when cases get into the appellate process. below you will find out some of the standards they use in evaluating your case.

IRS Hazards of litigation.

I am a former IRS agent and teaching instructor. I have over 40 years of experience with the Internal Revenue Service and in private practice. If you need help representation please feel free to call us today.

As a general rule after practicing over 40 years of tax experience, I have found I get a better result going to the appeals division. I feel that you have a more seasoned person looking at the case who is much more able to settle the case based on their years of experience. You will find the Appellate Division much more flexible.

Many times in the local office you do not know what you’re going to get from the field agent working the case. It is a lot easier many times to convince the appeals officer based on certain common senses. Many times a local office will see things black-and-white and the appeals agent sees things in the gray and are quicker to settle cases.

But keep in mind, you cannot have any frivolous arguments, you must have some sort of case before bringing it forward.

If you work a lot of cases that frequently go to appeals you can start building a reputation of a solid practitioner versus a scammer. It is best generally for your client and for your reputation to send solid work to the appeals office.

A LAYMAN’S LOOK AT THE HAZARDS PROCESS

I am attempting here to lay out a layman’s look at the hazards of litigation and what the appellate officer will look at as a case comes their way.

As a general rule, the appellate officer receives the entire case from the collection division or the audit division with all the notes and the entire case file.

Generally, the Appellate Division will get involved in the case from the audit or collection division in which the taxpayer is unsatisfied based on the result of the current field agent working the case and asked for a hearing in the appeals division.

The agent will carefully look at the case and then send out their appointment letter. They want to try to understand the case first before the appointment letters go out.

It is critically important for the practitioner of the taxpayer to respectfully and respond to all-time dated requests. You do not want to do anything to upset the appeals agent and their timelines in the handling of these cases.

Case files sent by the practitioner to appeals should be very organized, well documented and placed in tabs if necessary. Good case appearance is very important to the appellate agent can make their way through the case easily.

IRS management is very time conscious on cases and as a general rule, they do not like having overage cases in their inventory and many times both management and the agents are written up because of poor time management.

The appeals division is there to make a lasting final decision before the case could go to Tax Court.

The appeal officer does not want the case to go to court and they do their best to settle the case if in fact it can be settled on a reasonable basis. However,’s there are certain factors that the IRS appellate agent must consider before settlement.

If the case goes the Tax Court the IRS does not want to lose because it can alter future decisions and this can have a devastating effect on future cases going forward. If they lose the case it looks bad on the appellate agent, the supervisor’s management and the district in which the decision was ruled.

An Example:

The appellate agent looks at the case and based on the facts and circumstances. If feel they have an 8/10 chance of winning the case, many times they can offer an 80% reduction in the total tax. Before the agent sends out a letter offering a reduction, the case is reviewed with their supervisor to make sure this is consistent with the IRS overall goal so it does not affect future cases.

The IRS has certain categories or criteria that they use for the hazards of litigation.

I have put together 11 elements that they use in making their determination about the strength of the weakness of their case. Please remember this is a layman’s view so those reading this blog can understand how the IRS works these hazards of litigation cases.

I have deliberately not gone into any legal detail because this is just a brief overview of hazards.

Hazards of litigation categories

This list contains a majority of factors but not all-encompassing.

1. How would the judge view the facts of this case?

2. How much evidence would this hold inside a courtroom,

3. What is the credibility of the representation and the taxpayer

4. How well is the case been presented to the appeals agent that will be presented in court? Is the case well presented in well representative

5. Can the taxpayer meet the burden of proof effectively to convince the judge

6. If witnesses come into play are they credible and will they testify in such a case, can anything disqualify them

7. Has the taxpayer successfully shifted the burden of proof to IRS

8. Who does the appeals agent based on the aforementioned facts feel the judge will rule in favor of

9. How solid will the presenter of the taxpayer’s case be

10. Can the evidence of the facts be proven

11. Has tax law already existed in this case

What Does the IRM say about these matters

1. The Appeals mission is to resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer and in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the Service.

This is Appeals’ general contribution towards achieving the Service mission. (See IRM 1.1.1, IRS Mission and Basic Organization and IRM 1.2.17, Servicewide Policies and Authorities, Policy Statements for the Appeals Process.) In further support of the Service mission, Appeals may defer action on or decline to settle some cases, under Policy Statement 8–47 (described at IRM 1.2.17.1.6), where:

A. required by other Headquarters Office-issued internal management documents, such as those suspending action on cases or those requiring coordination or control of identified matters with widespread impact; or

B. such action would produce a greater positive effect on voluntary compliance than would be derived from settlement or other action on the case.

3. A fair and impartial resolution is one which reflects on an issue-by-issue basis the probable result in event of litigation or one which reflects mutual concessions for the purpose of settlement based on relative strength of the opposing positions where there is substantial uncertainty of the result in event of litigation.

4. It is the experience of Appeals that thorough, reasonable, and objective consideration of all elements of a controversy leads, in a large majority of cases, to the resolution of the controversy on a basis agreeable to both the taxpayer and the Government.

The agreement is not possible in all cases, however. A taxpayer may not agree with Appeals conclusion as to the probable result in event of litigation or to the extent of mutual concessions required where there is substantial uncertainty of litigating result or may prefer to litigate for other reasons.

If you are looking for professional tax help call us today for a free initial tax consultation and rest assured that you will receive the very best possible IRS tax audit or appellate defense.

Former IRS Agents + IRS Appellate Experts & Tax Defense + Ft.Lauderdale, Miami, Palm Beaches, Boca Raton, Aventura

IRS Appeals Experts + IRS Tax Audit, IRS Collection Cases + Ft. Lauderdale, Miami, Boca Raton, Miami Beach, Palm Beaches

Fresh Start Tax

We are a local tax firm that has been practicing in South Florida since 1982. We are composed of CPAs, former IRS agents, managers, and teaching instructors.

 

IRS Appeals Experts + IRS Tax Audit, IRS Collection Cases

We are one of the most affordable and experienced professional tax firm in South Florida and dealing with the Internal Revenue Service. We have worked thousands of IRS tax cases since 1982.

 You can feel free to come by our office is Skype us or call us for a free initial tax consultation. You will be provided with the very best IRS tax defense for IRS audits, IRS collections, or any appellate work.

We have over 200 years of professional tax experience and over 100 years of working directly for the Internal Revenue Service and the local, district, and regional offices of the Internal Revenue Service.

Our former IRS agents worked as managers and supervisors in the IRS tax audit division and we know every single way imaginable way to provide you the best possible tax defense if you are going through a IRS tax audit.

If you have received a letter from the Internal Revenue Service stating that you are going through an IRS tax audit, contact us today and we will walk you through the process of what to expect and how to prepare the best tax defense.

If you wish to appeal the findings of the local IRS agent, we can provide the best possible appellate tax defense for going forward.

Call us today for a free initial tax consultation and understand why we are considered the best IRS tax audit help the fence in South Florida.

Many people ask us how IRS determines their cases when cases get into the appellate process. below you will find out some of the standards they use in evaluating your case.

 

IRS Hazards of Litigation.

I am a former IRS agent and teaching instructor. I have over 40 years of experience with the Internal Revenue Service and in private practice. If you need help representation please feel free to call us today.

As a general rule after practicing over 40 years of tax experience, I have found I get a better result going to the appeals division. I feel that you have a more seasoned person looking at the case who is much more able to settle the case based on their years of experience. You will find the Appellate Division much more flexible.

Many times in the local office you do not know what you’re going to get from the field agent working the case. It is a lot easier many times to convince the appeals officer based on certain common senses. Many times a local office will see things black-and-white and the appeals agent sees things in the gray and are quicker to settle cases.

But keep in mind, you cannot have any frivolous arguments, you must have some sort of case before bringing it forward.

If you work a lot of cases that frequently go to appeals you can start building a reputation of a solid practitioner versus a scammer. It is best generally for your client and for your reputation to send solid work to the appeals office.

 

A LAYMAN’S LOOK AT THE HAZARDS PROCESS

I am attempting here to lay out a layman’s look at the hazards of litigation and what the appellate officer will look at as a case comes their way.

As a general rule, the appellate officer receives the entire case from the collection division or the audit division with all the notes and the entire case file.

Generally, the Appellate Division will get involved in the case from the audit or collection division in which the taxpayer is unsatisfied based on the result of the current field agent working the case and asked for a hearing in the appeals division.

The agent will carefully look at the case and then send out their appointment letter. They want to try to understand the case first before the appointment letters go out.

It is critically important for the practitioner of the taxpayer to respectfully and respond to all-time dated requests. You do not want to do anything to upset the appeals agent and their timelines in the handling of these cases.

Case files sent by the practitioner to appeals should be very organized, well documented and placed in tabs if necessary. Good case appearance is very important to the appellate agent can make their way through the case easily.

IRS management is very time conscious on cases and as a general rule, they do not like having overage cases in their inventory and many times both management and the agents are written up because of poor time management.

The appeals division is there to make a lasting final decision before the case could go to Tax Court.

The appeal officer does not want the case to go to court and they do their best to settle the case if in fact it can be settled on a reasonable basis. However,’s there are certain factors that the IRS appellate agent must consider before settlement.

If the case goes the Tax Court the IRS does not want to lose because it can alter future decisions and this can have a devastating effect on future cases going forward. If they lose the case it looks bad on the appellate agent, the supervisor’s management and the district in which the decision was ruled.

An Example:

The appellate agent looks at the case and based on the facts and circumstances. If feel they have an 8/10 chance of winning the case, many times they can offer an 80% reduction in the total tax. Before the agent sends out a letter offering a reduction, the case is reviewed with their supervisor to make sure this is consistent with the IRS overall goal so it does not affect future cases.

The IRS has certain categories or criteria that they use for the hazards of litigation.

I have put together 11 elements that they use in making their determination about the strength of the weakness of their case. Please remember this is a layman’s view so those reading this blog can understand how the IRS works these hazards of litigation cases.

I have deliberately not gone into any legal detail because this is just a brief overview of hazards.

 

Hazards of litigation categories

This list contains a majority of factors but not all-encompassing.

1. How would the judge view the facts of this case?

2. How much evidence would this hold inside a courtroom,

3. What is the credibility of the representation and the taxpayer

4. How well is the case been presented to the appeals agent that will be presented in court? Is the case well presented in well representative

5. Can the taxpayer meet the burden of proof effectively to convince the judge

6. If witnesses come into play are they credible and will they testify in such a case, can anything disqualify them

7. Has the taxpayer successfully shifted the burden of proof to IRS

8. Who does the appeals agent based on the aforementioned facts feel the judge will rule in favor of

9. How solid will the presenter of the taxpayer’s case be

10. Can the evidence of the facts be proven

11. Has tax law already existed in this case

What Does the IRM say about these matters

1. The Appeals mission is to resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer and in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the Service.

This is Appeals’ general contribution towards achieving the Service mission. (See IRM 1.1.1, IRS Mission and Basic Organization and IRM 1.2.17, Servicewide Policies and Authorities, Policy Statements for the Appeals Process.) In further support of the Service mission, Appeals may defer action on or decline to settle some cases, under Policy Statement 8–47 (described at IRM 1.2.17.1.6), where:

A. required by other Headquarters Office-issued internal management documents, such as those suspending action on cases or those requiring coordination or control of identified matters with widespread impact; or

B. such action would produce a greater positive effect on voluntary compliance than would be derived from settlement or other action on the case.

3. A fair and impartial resolution is one which reflects on an issue-by-issue basis the probable result in event of litigation or one which reflects mutual concessions for the purpose of settlement based on relative strength of the opposing positions where there is substantial uncertainty of the result in event of litigation.

4. It is the experience of Appeals that thorough, reasonable, and objective consideration of all elements of a controversy leads, in a large majority of cases, to the resolution of the controversy on a basis agreeable to both the taxpayer and the Government.

The agreement is not possible in all cases, however. A taxpayer may not agree with Appeals conclusion as to the probable result in event of litigation or to the extent of mutual concessions required where there is substantial uncertainty of litigating result or may prefer to litigate for other reasons.

 

IRS Appeals Experts + IRS Tax Audit, IRS Collection Cases + Ft. Lauderdale, Miami, Boca Raton, Miami Beach, Palm Beaches

Owe Back Tax Debt To IRS/State + Options For Fast Relief + Accounting, CPA’s, Debt Relief Company + Ft. Lauderdale, Miami, Boca Ration, Pembroke Pines

Fresh Start Tax

If you owe back taxes to the Internal Revenue Service you have several options to resolve your back tax debt. As a former local IRS agent, here are your options for relief.

 

Since 1982, we have been practicing right here in South Florida. As former IRS agents managers and teaching instructors worked out of the local South Florida IRS offices as well.

 

Millions of taxpayers owe back taxes every year to the Internal Revenue Service and best guess estimates show there’s anywhere between 5 to 10 million people who do not fully pay their income taxes when filed.

They generally fall into two categories of people, those who have not had sufficient withholding taken out or self-employed individuals who simply never made or did not have enough estimate payments made to the Internal Revenue Service to cover their tax debt.

Both find themselves on the short end of the stick when it comes to tax season.

Many of these taxpayers never bother to file a tax return when they find out they owe tax fearing the worst or retribution from the Internal Revenue Service.

Many of these people fear the IRS levy on their bank or their wages or the filing of a federal tax lien. So what do most of these people do, many put their head in the sand and don’t bother to go ahead and do anything about the inevitable debt. However at some point in time they are going to have to deal with Uncle Sam and many will receive a nasty gram.

The fear is not as bad as people think. You have different options to resolve your IRS back tax debt and keep IRS out of your life and out of your back pocket.

Here are your different options if you owe back tax debt to the Internal Revenue Service.

About 6.5 million taxpayers a year make monthly installment agreements. Some of these can come in the form of online agreements. the ones do not fit the online agreement category must give IRS a current financial statement documented along with copies of pay stubs bank statements and they must understand the necessary living expense standards set up by Internal Revenue Service.

IRS will require a financial statement which is generally on a 433F to be fully reviewed fully documented before making a determination on allowing them to make an installment agreement.

Others simply cannot pay their back taxes and will ask IRS to be put in a hardship or are currently not collectible status. Those individuals going in the status must understand that the tax debt will be reviewed again in two or three years and penalties and interest will still run on the debt the entire time it is an uncollectible status.

Others can file for an offer in compromise to settle their tax debt for pennies on a dollar. With that said you must be a truly qualified candidate for the offer in compromise program.

As a former IRS agent, I was a teaching instructor for the offer and you must make sure you are a qualified candidate and not give your money to any firm unless you know you have a fair amount a chance to get your offer accepted

If you have any questions regarding owing back tax debt and the best way to resolve it based on your current financial statement please call us today for a free initial tax consultation and we will review with you the various programs IRS has in detail so you fully understand what the best option for you based on your current financial conditions.

If you are hiring a tax firm or a tax defense resolution company to represent you make sure they have former IRS agents on staff.

Check the Better Business Bureau records find out the length of time they been in business and check out the complaint history.

And lastly speak to the person who may be working your case. call us today for a free initial tax consultation and hear the truth about owing back taxes to the IRS or state.

Owe Back Tax Debt To IRS/State + Options For Fast Relief + Accounting, CPA’s, Debt Relief Company + Ft. Lauderdale, Miami, Boca Ration, Pembroke Pines

Affordable IRS Back Tax Debt Relief Help + Christian IRS/State Tax Experts + Ft. Lauderdale, Miami, Boca Raton, Palm Beaches, Pompano Beach

Fresh Start Tax

Michael Sullivan IRS Tax Debt Expert, File & Settle Your Tax Debt all At the Same Time <><

 

We are a South Florida tax firm that specializes in affordable IRS  and state tax defense firm that specializes in affordable IRS back tax debt help and relief including the filing of all tax returns.

We have 200 years of professional tax experience in over 100 years of working directly for the Internal Revenue Service as agents, supervisors, managers, teaching instructors, appeals experts, and all facets of the internal workings with the Internal Revenue Service.

We’ve been practiced in South Florida since 1982 and have over 200 years of professional tax experience in over 100 years of working directly for the Internal Revenue Service and the local, district, and regional tax offices of South Florida.

We are one of the most elite and premier firms in the tax debt relief industry.

We provide fast, affordable and the results taxpayers are expecting based on their current financial situation because we know all the methodologies behind how IRS works all cases.

Feel free to ask us about our Christian faith when you call.

When I was employed by the Internal Revenue Service I work the offer in compromise program. there are three general programs to settle your tax debt, the offer in compromise, the payment agreement and the hardship program but before IRS accepts any of these programs you must have all your tax returns filed and up-to-date.

As a general rule, the IRS looks at your current financial statement to determine what status they will close out your case off the enforcement computer.

Some taxpayers can qualify for an online payment agreement and when you call for your free initial consultation we will let you know if you qualify.

Approximately 6.5 million taxpayers are put into qualified payment agreements every year while 45% of all open collection cases wind up in a hardship, or currently uncollectible.

Approximately 32,000 people year settle their tax that for approximately $9500.

When you call our office we will review the various programs and find out what program you qualify for based on your current financial condition.

We can prepare all back tax returns with or without records get them on the IRS computer and settle your tax debt all at the same time.

As a result, we know all the inside secrets the methodologies and all the back tax programs to settle back taxes available.

Not only did I accept and reject offers in compromise, I was also a teaching instructor at the service center to help qualified revenue officers decide which offers to accept and reject.

Given the above information, I can tell you I am a true expert for the IRS offer in compromise and I wish to explain to you whether an offer in compromise is a viable option for you.

Due to social media, marketing and advertising the assumption by the general public is that IRS can settle tax debt for pennies on the dollar.

Let me first let you know that IRS does accept offers in compromise and as a matter of fact last year approximately 32,000 offers in compromise were accepted out of the 78,000 that were filed.

That number varies from year to year but the percentages usually remain the same of acceptability.

The average settlement was $9500 per case but remember that is just an average in not everybody can settle their tax debt for $9500.

There is much information you need to know before you go off filing an offer of compromise and giving your money to some firm to try to pull off some amazing trick because you have been sold a bill of goods and bought in to some marketing ploy and they’ve convinced you are a settlement candidate.

 

The IRS Process:

It first starts with the review of your personal financial statement which is found on the 433 OIC.

When the offer in compromise gets sent in to the Internal Revenue Service it is met with the reviewer that make sure that you are truly qualified candidate for the offer in compromise program.

That reviewer checks the completed form to make sure it is a valid agreement. The offer in compromise is a legal document between you and the Internal Revenue Service.

If IRS were to accept the offer and the next day you win the lottery the accepted offer still stands.

Also reviewer make sure that all the documentation is attached so that the revenue officer who will work your offer in compromise can move forward.

Approximately one-third of all offers in compromise are sent back to the taxpayer because the offers are not filled out correctly or the appropriate documentation is not attached.

IRS will check to make sure all your tax returns are current and filed on the IRS system.It is critically important you know that you must have all tax returns filed before IRS will process your offer.

You should know that the Internal Revenue Service rejects an offer before it accepts an offer. one of the basic rules is that the revenue officer is lazy and is easier to mark rejected then they go through all the work of accepting an offer in compromise.

I should know this is a former instructor of the offer in compromise I see many revenue officers simply send offers back because some of the eyes were not dotted in the T’s were not crossed.

Due to the volume of cases the IRS has, which is over 7500 cases waiting in the IRS Q, is far easier for the IRS to say no then to accept because an average of anywhere between 20 and 40 hours are spent on accepting the offer in compromise.

If you have an offer in compromise accepted, four signatures are generally required for signature as it goes up and down the chain.

So how do you know if the offer in compromise is right for you. Call for a free initial tax consultation and hear the truth from a true IRS tax debt settlement former agent.

The first place to go is to fill out the IRS pre-qualifier tool for the offer in compromise. Because of so many scrupulous tax companies that have been ripping people off, the IRS wanted to make sure the general public has a tool that they can use to find out if they are prequalified to file the offer in compromise to make sure it is a viable option.

It contains all the necessary information in regard to your income, your expenses and your assets and it predetermined for you whether the offer in compromise is even a viable option for you.

IRS will take a very close look at the liquidity of your assets, your current income, and your monthly expenses before it renders a decision as IRS wants to make sure it collects all the money from you that they can within the 10 year statutory period of time.

One of the questions the agent will want to consider is, can we collect more money over 10 years than accept the current agreement on the table for the IRS offer in compromise.

As a general rule, you will have to give IRS your total liquidity of all your assets before they will even consider the acceptance of an offer in compromise.

IRS on larger dollar cases is a tremendous amount of due diligence. The IRS has a wealth of information on the various computers they can use to dig and find assets or income.

Why? you may ask is because all offers in compromise are open for public inspections at eight regional offices throughout the United States.

Your offer in compromise must be thoroughly documented which includes all your bank statements for the last six months to a year, all your pay stubs, all your monthly expenses along with certain documentation for assets that have value.

IRS also takes a look at the values of your pensions, your IRA, your business as well.

The offer in compromise is one of the most reviewed documents, it is like going through a mini audit.

Some of the due diligence that IRS will conduct on a larger dollar cases is checking Google, the accurate search engine, Department of Motor Vehicles, real estate records, insurance policies, credit reports, loan applications, insurance policies, and inter-government agency records including those garnered by Homeland security and other such agencies.

Before you contemplate filing the offer in compromise and wasting your money on a company that has promised you they can settle your case for pennies on the dollar, you would be wise to give us a call to have an actual former IRS agent and teaching instructor of the offer in compromise give you the green light.

You should also know if an offer in compromise is not except that you have the right to appeal it and if the appeal is not accepted you can file an offer at a later time.

When you call our office you will speak to true IRS tax experts who knows the system and can tell you what to expect and tell you how to settle for the lowest amount possible.

When you call our office will review every single back tax program available, and generally there’s three the hardship program the payment agreement program and the most popular back tax program the offer in compromise which completely settles your IRS tax debt but you must be a candidate that fits the IRS criteria.

Call us today for a free initial tax consultation, you will hear nothing but the truth from former IRS agents who know and understand the methodologies of the offer in compromise to make sure it is right for you.

Please feel free to come into our local office, Skype us or call us for a free initial tax consultation. You will hear the truth from one of South Florida’s  premier IRS back tax debt relief firms who provide affordable tax help.

 

Affordable IRS Back Tax Debt Relief Help + Christian IRS/State Tax Experts + Ft. Lauderdale, Miami, Boca Raton, Palm Beaches, Pompano Beach