Reversal of IRS Seriously Delinquent Tax Debt Certification
The IRS certified Taxpayer’s individual federal income tax debt as seriously delinquent under IRC Section 7345. Taxpayer was notified by IRS Notice 508C. DeWitt Law represented Taxpayer before the IRS and challenged the seriously delinquent certification. The IRS issued IRS Notice (pictured below) and reversed the seriously delinquent tax debt certification.
$313,821 Tax Debt Settled for $8,359
Represented taxpayer who owed the IRS over $313,821. Tax debt was reduced to $8,359 through an accepted offer in compromise.
Resolution of Unfiled Federal Income Tax Returns Resulting in Substitute Tax Returns
Taxpayer failed to file federal income tax returns for several years despite earning substantial self-employment income. The IRS filed substitutes for return (“SFR”) and a Notice of Deficiency, assessing tax. DeWitt Law represented the Taxpayer and challenged the tax assessment in U.S. Tax Court. The SFR returns were set aside and the IRS accepted reconstructed tax return filings. The SFR assessment was reversed and the Taxpayer paid the balance due…
IRS Due Diligence Audit – No Penalties Assessed
Represented tax preparer and owner of tax preparation franchise who was audited by the IRS for compliance with tax preparation due diligence rules. The IRS proposed penalties against Client in the amount of $60,840 for alleged violations. DeWitt Law appealed and the IRS reversed the assessment to $0.
IRS Audit Involving Re-Constructed Expenses – No Additional Tax Assessed
Represented self-employed contractor in field audit covering a 3-year period. Client had limited records so business mileage, supplies, and contract labor expenses had to be re-constructed. The IRS proposed a six-figure tax assessment in its original audit report. Case was appealed and the IRS reversed virtually all of the proposed assessment, allowing the re-constructed expenses.