Mr. Hoyt is a Board Certified Tax Law Specialist recognized by the Louisiana State Bar Association since 1990. He received his Masters of Tax Law degree from Georgetown University in 1979. While in Washington, he worked for the National Office for the IRS. Thus his unique qualifications and experience offer him tremendous insight in working with the IRS. Contact us for tax law guidance.
Most tax assessments begin at the Tax Audit phase. An Audit occurs generally as a result of a computer program by the IRS targeting the taxpayer’s return as having some financial information that fits the criteria as established by the computer as being subject to a high risk of noncompliance by taxpayers.
Once an audit is concluded by an agent, the next process is a meeting with the manager of the agent to negotiate with the manager to resolve the differences.
In the event that an IRS Audit cannot be resolved successfully for a taxpayer at the local level, there is an Appeals procedure whose job is to try and settle cases prior to litigation. Most Appeals are done via correspondence with telephone conferences but sometimes it is more advantageous for the taxpayer to appear in person.
Tax Court Litigation
After the Appeals process, there is the U.S. Tax Court or the U.S. District Court in which the issue can be litigated. To go to District Court, the tax must be paid and the taxpayer must sue for a refund. At the Tax Court, no tax has to be paid before the assessment can be contested.
Tax Liens and Levies
Once the tax amount is finalized, then the collection phase begins. The IRS has a variety of collection techniques including the use of tax liens on all of the taxpayer’s property planet wide and levies of bank accounts and interest in business entities.
Offers In Compromise
Offers In Compromise is a program the IRS has to allow the taxpayer to pay off the amount due in less than a full payment or in multiple installments. This is available if the taxpayer has a lack of assets or income to satisfy the tax.
IRS Installment Agreements
Installment agreements can be entered into by the IRS to agree to pay a certain amount monthly to prevent garnishment of a taxpayer’s wages.