Below are brief synopses of articles written by Tony Mankus regarding various IRS/tax issues.*
IRS Restructuring and Reform Act of 1998: Following public hearings by the Senate Finance Committee in 1998, Congress passed the IRS Restructuring and Reform Act in order to address problems and perceived abuses expressed by various sectors of the practitioner community, employees and/or representatives of the IRS, as well as private individuals and businesses. This article examines most of the Act's provisions dealing with tax collection issues.
IRS Seizure: This article deals with many of the issues, both legal and practical, related to collection of taxes by physical seizure of property from delinquent taxpayers.
IRS Sale: This article explores the various aspects and issues related to sale of property seized by the IRS from taxpayers or their businesses.
IRS Levy: This article addresses the issues related to IRS levies on property of taxpayers in the hands of third parties, such as bank accounts, wages, accounts receivables, insurance proceeds, retirement benefits, etc.
IRS Lien: This article addresses many of the complex issues related to the Federal Tax Lien and the impact it has on property of taxpayers. (This article is still not complete.)
Trust Fund Recovery Penalty: (Formerly known as "The One Hundred Percent Penalty.") This article explores the details related to IRS' ability to pierce the corporate veil and collect a portion of its unpaid payroll taxes from "responsible" individuals, such as officers, stockholders and directors.
Sale of Property Encumbered by a Federal Tax Lien: This article examines how property encumbered by a federal tax lien may be sold to a third party.
Dischargeability of Taxes in Bankruptcy: Unlike the belief held by much of the public, income and other taxes may be discharged in bankruptcy under the proper circumstances. This article examines how this can be accomplished and the limitations related thereto.
IRS' Corporate Culture: This article, the author's most personal and subjective, was written prior to the passage of the Restructuring and Reform Act of 1998. It examines how many of the negative and frustrating aspects of dealing with the IRS came to be. The Restructuring and Reform Act was intended to address many of the problems discussed there.
*Note: These articles are not to be construed as legal advice. They are intended to be, for the most part, scholarly examinations of the issues discussed. They should not be relied on to deal with the IRS in specific situations which may be different in significant respects. In addition, laws and procedures change and the author cannot guarantee that some issues discussed in the articles have not been affected by those changes. It is always best to retain competent counsel to deal with your specific situation.
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