A few years ago, while serving as the Commissioner of the Small Business/Self-Employed (“SBSE”) Division (“Collection”), I took a call from a tax attorney whose client was unable to renew his passport. The client found himself in this predicament because of an unresolved, large balance due to the Internal Revenue Service (“IRS”), one that had…
In the News
IRS Modernizes Collection: What’s Next for Tax Practitioners
Tax practitioners need to be prepared for a shifting landscape in the IRS’s collection efforts in 2026 and beyond. The last several months have made clear that, despite the IRS facing personnel cuts and work stoppages due to the government shutdown, the agency’s collection efforts continue to remain a top priority. Read Full Article >
Tax-Exempt Companies Ignoring Current Climate Do So at Own Peril
Whether you’re a small entity previously reliant on government grants or a large organization with policies drawing near the epicenter of current cultural debate, tax-exempt organizations should tend to their garden. And the ground is moving beneath our feet. Read Full Article >
IRS Criminal Investigation Division Releases “Top Ten” Cases of 2024, Signs Point to Focus on Employment Tax Fraud and Bank Secrecy Act Violations
Earlier this year, the Internal Revenue Service’s Criminal Investigation division (IRS-CI) released its “top ten” cases of 2024. The cases involved a myriad of issues, such as fraudulent use of tax shelters, money laundering, and embezzlement charges. Read Full Article >
Supreme Court Grapples With Taxpayers’ Due Process Rights in Zuch
In this article, Guillot analyzes whether a pending collection due‑process proceeding becomes moot when the underlying tax liability is satisfied through involuntary payments, as in Zuch, or through voluntary up‑front payments by the taxpayer to avoid the accrual of interest. Click here to read full article
