IRS debt
Continuation Theory: Collecting Taxes Owed by Prior Business
If a business has or expects to have a significant debt, it may transfer its assets and/or operations to a new business entity to try to avoid the debt. There are a number of non-tax cases where the courts have addressed this. The courts generally apply a “continuation” theory in these cases which asks whether […]
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Court Invalidates Longstanding Process to Challenge IRS Levy
If the IRS fails to mail or mails a notice to a taxpayer and uses the wrong address, should the taxpayer be faulted for missing the deadline set out in the IRS notice? The Seventh Circuit Court of Appeals says “yes” in Adolphson v. Commissioner, No. 15-2242. The facts and procedural history are as follows: […]
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IRS Collections for U.S. Military Personnel
Judicial and administrative proceedings are temporarily suspended for those serving in the United States military. This includes a temporary hold on IRS collection actions. These laws are not provided in the Tax Code. Rather, they are set out in the Se…
TIGTA Review of the IRS’s Practices in Levying on Social Security Payments
The IRS has the power to levy on or take a taxpayer’s property. This includes nearly all property, including Social Security payments. The Treasury Inspector General for Tax Administration (TIGTA), the agency that audits the IRS, recently released a report that examined the IRS’s practices in levying on Social Security payments. Social Security Payments TIGTA’s[…]
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Stock Sale Triggers Transferee Liability for Buyer’s Tax Liability
In Marshall v. Commissioner, T.C. Memo. 2016-119, the U.S. Tax Court concluded that business owners who sold their stock was liable for the buyer’s Federal income taxes that arose after the sale. The facts and procedural history are as follows: The taxpayers owned Marshall Associated Contractors, Inc. (MAC), which was subject to tax as a […]
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