Straddle-Year Tax Debts in Bankruptcy: Does the King Get Paid First? [More with McGlinchey, Ep. 14]
On June 12, 2025, the U.S. Supreme Court issued a significant decision in Commissioner of Internal Revenue v. Zuch, clarifying the jurisdictional boundaries of the U.S. Tax Court in Collection Due Process (CDP) appeals....more
Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more
Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more
A Taxpayer’s U.S. Passport could be in jeopardy if the U.S. Taxpayer has seriously delinquent tax debt. The law authorizes the IRS to certify seriously delinquent tax debt to the U.S. State Department for the State...more
Sometimes, yes. At least that’s one takeaway from the argument in a recent U.S. Supreme Court case, Boechler, P.C. v. Commissioner of Internal Revenue. ...more
Once the IRS makes an assessment against a taxpayer, the taxpayer will receive several notices before the IRS takes enforced collection action....more
A topic that doesn’t get a whole lot of attention from tax professionals is “Currently Not Collectible” (“CNC”) status, which is a status that your account with the IRS may obtain when you cannot currently afford to pay the...more
Many taxpayers (if not all) would agree with the sentiment expressed on a wall plaque that recently caught my eye: “Dear IRS: I would like to cancel my subscription. Please remove my name from your mailing list.” That feeling...more
The IRS collection process begins when IRS does not receive full and timely payments from a taxpayer after it issues a collection notice. Based on the information in the taxpayer’s 1040 tax return, if the taxpayer does not...more