Representation when an IRS Revenue Officer has your case

A Revenue Officer works one account face to face, where the Automated Collection System works accounts by phone and letter. The IRS describes the officer’s job as helping resolve taxes owed and telling you about your rights, obligations, options and consequences. The officer may visit your home or business, though the IRS says unannounced visits are rare and an appointment letter or call normally comes first.

The officer can ask you to bring books and records or produce documents for a Collection Information Statement. If records are not produced, the officer can issue a summons, and the IRS may sue in federal district court to make you comply with it.

The firm works cases on both sides of IRS collection. Its description of the practice says it “represents taxpayers locally and throughout the United States,” which matters because a field case is assigned wherever the taxpayer is, and an Enrolled Agent can appear before any IRS office.

Form 433-A is the Collection Information Statement for wage earners and self-employed individuals, and Form 433-B is the version for businesses. Both list income, monthly expenses, bank accounts, assets and debts, and the officer may then ask for verification of each item: statements, pay stubs, titles, loan balances.

The form is signed under penalty of perjury, and its figures drive everything after it, from the monthly payment the IRS expects to whether an Offer in Compromise is worth preparing. A rushed statement that overstates income, or leaves out a legitimate expense, can set a payment the household cannot keep.

That is the third of the firm’s five steps: income, expenses and assets reviewed before the form goes to the officer, and the form prepared with the IRS’s expense standards in view.

A Revenue Officer sets dates for what the case needs: missing returns, the financial statement, supporting documents, a payment. The dates are the officer’s own and they move the case, so the first job after Form 2848 is filed is to collect them in one place and meet each one or ask for more time before it passes.

Disagreement has a defined route. For a lien, levy or seizure action, you can ask for a conference with the officer’s manager. If that doesn’t settle it, Form 9423, the Collection Appeal Request, must be received or postmarked within 3 business days of the conference, or collection may resume. If no manager contacts you within 2 business days of your request, you can go to Appeals directly, filing within 4 business days of the request.

This is general information; what an officer asks for in your case depends on its facts.

Large balances and unpaid payroll taxes both raise the stakes of an officer’s questions. For a balance over $100,000, the firm’s position is that “a substantial IRS balance does not automatically eliminate your resolution options.” The work is in proving which option the numbers support.

Unpaid payroll tax adds a personal question. When a business doesn’t pay over the income tax and the employees’ share of Social Security and Medicare it withheld, the officer investigates who was responsible, and 26 U.S.C. § 6672 lets the IRS assess the Trust Fund Recovery Penalty against those people personally, equal to the unpaid trust fund amount. A proposed assessment arrives on Letter 1153. The details are on the payroll page.

Once Form 2848 is filed, Tyrone J. Taylor is the officer’s point of contact for the matters and years it lists. He reads the transcripts for each year’s assessments, penalties and collection statute date, gathers the officer’s deadlines, prepares the Form 433-A or 433-B with you, and proposes the resolution the figures support, whether an installment agreement, an offer or Currently Not Collectible status.

Current compliance is part of the proposal, since an officer will expect this quarter’s deposits and this year’s estimated payments to be made while the old balance is negotiated. Kenneth S. wrote, “I would not trust anyone else to handle my tax situation”. The rest of the process is on the IRS representation page.