Collections, Liens & Levies

Offer in compromise not deemed accepted

An offer in compromise submitted during a Collection Due Process proceeding is not deemed accepted under Sec. 7122(f) if it is returned to the taxpayer within 24 months of submission.

Passport revocation as a collection tool

Taxpayers can lose their US passports over unpaid tax debts meeting certain criteria, and courts have only limited jurisdiction to review a certification or remedy it.

Penalty defenses and the supervisory-approval requirement

Under Sec. 6751(b)(1), many penalties cannot be assessed by the IRS before written managerial approval is obtained by the immediate supervisor of the person making the initial determination of the penalties. This article discusses which penalties Sec. 6751(b)(1) applies to, when an initial determination of a penalty occurs, whose approval is required, and other issues regarding the written-supervisory approval requirement.

Tax Insider Articles


Business meal deductions after the TCJA

This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.


Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.