A Tax Attorney Can Help You Strike the Right Balance Between Cooperating With the IRS and Fighting for Your Rights

The old adage “you catch more flies with honey than with vinegar” applies very well for taxpayers dealing with an Internal Revenue Service (IRS) Revenue Officer—a highly trained and skilled employee of the IRS’s collection division. While their job is to follow the Internal Revenue Code and other mandated guidelines, a fair amount of subjectivity is involved in the process. As a result, cooperating with a Revenue Officer can often lead to a more timely resolution of your case. However, cooperation does not automatically mean that you have to agree with everything the Officer says or does. A lawyer can help you strike the right balance.

An Experienced Tax Attorney Can Help You Work With a Revenue Officer

An attorney can help you work toward one of the three outcomes:

  1. A payment plan with payment amounts that you can afford. Payment plans are not unheard of when dealing with the IRS. However, there can be significant inconsistency with regard to the amount of each monthly payment. Obviously, as a taxpayer, you prefer to keep this payment amount as low as possible. Even though Revenue Officers are expected to apply facts and circumstances to each case, results still vary greatly between taxpayers. Fortunately, an experienced lawyer can help you negotiate the best possible terms.
  2. Placement into a protected status. If you are unable to afford your current tax liability, your attorney may be able to work with the Revenue Officer to demonstrate that you should be placed in “Currently Not Collectible” status. This decision is made based on the unique facts and circumstances surrounding your case and will protect you from any further collection actions by the IRS. It does not eliminate the debt—a lien can be filed before the account is declared Currently Not Collectible if the debt is in excess of $5,000 or the Revenue Officer believes that you may be able to pay it in the future.
  3. Obtain an extension on full payment. Your attorney can work with the Revenue Officer to delay the full payment of the liability for a variety of reasons. For example, an extension may be granted if you can demonstrate that there is reasonable doubt as to the correctness or validity of the tax assessment.


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Travis Watkins
Senior Tax Attorney
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