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TOPICS / PROCEDURE

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.

IRS voice bots help set up payment plans

The IRS deploys more AI-powered phone abilities, enabling taxpayers calling the Service to authenticate their identifies and arrange to pay tax liabilities.

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.