The Dreaded Notice of Deficiency

An IRS Notice of Deficiency is a proposed increase in your taxes and a notice of your right to challenge that increase. It’s also called a CP3219A letter. No one likes getting these notices. Who wants to be told by the biggest collection agency in the world, the IRS, that you owe them more money? …

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IRS Trust Fund Recovery Investigations

You may be facing a trust fund recovery investigation because you didn’t pay the 941 taxes. The IRS considers this a loan they didn’t agree to. They don’t like making loans. A trust fund recovery investigation is governed by the Internal Revenue Manual 5.7.4 Investigation and Recommendation of the TFRP. They are conducted by the …

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Personal Liability for Unpaid Trust Fund Taxes

Trust fund taxes also called 941 taxes or employment taxes, must be withheld by an employer from an employee’s wages or salary and timely paid to the IRS. You hold them on behalf of your employees, hence the trust fund categorization. If the trust fund taxes are not collected, accounted for and paid to the …

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IRS Third Party Summons and How to Deal With Them

So you just got notice that the IRS issued a summons to your spouse, a family member or someone you do business with such as a bank, supplier or client of yours. I bet your first response was embarrassment and your second response was fear. Both valid. The IRS can issue a third party summons …

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The Truth About an IRS Offer In Compromise (OIC)

So you are in trouble with the IRS and you see those commercials on TV and hear those radio advertisements telling you that they can settle your IRS debt for pennies on the dollar. Sounds good, right? Well, the truth is that the IRS rarely settles for pennies on the dollar. It can happen, I …

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Have you been served with an IRS Summons?

  Have you been served with an IRS summons to produce documents or to appear and give testimony? The first thing you should absolutely do is LAWYER UP, LAWYER UP, LAWYER UP! Get a tax defense attorney that is experienced in fighting the IRS. When you are served with an IRS summons, you should never …

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Martial Arts Practice in Law

For anyone actually following my online ramblings at this site or one of my other sites, knows that I am heavily involved in martial arts. I have been doing so¬†for many moons now. My martial arts practice preceded my law practice. But, the two, in essence, hold the same philosophy. They are branches of the …

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Tax Resolution Companies: Some Frightful Experiences

Over the years, I have had clients retain me after they had already paid for the services of a tax resolution company. The most common complaint I hear is that the tax resolution company charged the client for taking on the case but never did any work leaving the client in a worse situation than …

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The Meaning of Frivolous in IRS Tax Protestor cases

Having dealt with a number of tax protestors, I have noticed one thing common among all of them and something they take great offense towards. Its the use of the term “frivolous”. The IRS classifies tax protester arguments as “frivolous” arguments. I have tried to explain this term to tax protestors because there is a …

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My Fascination with Sovereign Citizens

I have dealt with and represented people that are part of the sovereign citizen movement. Its fascinating and their ideas about the law and living in the United States are quite radical. My introduction to the sovereign citizen’s movement first came about many years ago while I was working at a law firm doing immigration, …

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