John Dillard is an author and Certified Public Accountant. To See how he takes Christ along with him to work visit www.HisCPA.com
September 15th, 2009 10:20 AM ET
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100%/Civil Penalty When Addressing IRS Representation Issues & an Offer in Compromise

100%/Civil Penalty When Addressing IRS Representation Issues & an Offer in Compromise

When you are readying yourself for IRS Representations Issues, Getting an Installment Plan Established, or when submitting an Offer in Compromise it is prudent to be aware of have already assessed to the taxpayer any and all 100%/Civil Penalties so that your Taxpayer Advocate/CPA does not have to handle critical and essential tax issues twice. Below is a sample of a letter that might be used to have the IRS assess the responsible taxpayer penalty to ensure that all monies "are on the table" and that otherwise addressable issues do not spoil an otherwise positive IRS representation experience. For example, finding there are other unpaid taxes will void an Offer in Compromise, Installment Plan and a payment strategy to address otherwise potentially solvable issue.

Internal Revenue Service
Cincinnati, OH 45999-0013

RE: ABC Company, Inc., FEI # 00-0000000

Enclosures: Power of Attorney

Dear Sir or Madam,

I am writing you in a good faith attempt to come to terms over the above taxpayers' present predicament with the IRS and to request that all unpaid payroll taxes of the company for all periods and years be assessed to the Mr. ______________ SS # ________________ as a Civil Penalty as they are the sole responsible party.

ASAP after these monies are assessed I plan to submit an Offer in Compromise on their behalf. I am willing/eager to supply you with any information that you might need in order expedite assessment of the 100% Penalty/Civil Penalty.

Also when you are assessing these monies please send to me copies of all assessments while ensuring that we have a list of all outstanding payroll taxes for the company.

Please cease all collection efforts while the 100% Penalty is being assessed and please do not hesitate to contact me should you have any questions.

Sincerely,
John C. Dillard, CPA, PC
Partner in Charge

To learn more about addressing IRS Tax Issues and Back Tax Returns visit http://www.hiscpa.com/working-with-the-irs.html

John Dillard is an Christian Speaker/Author and Certified Public Accountant in Duluth, GA. To See how he takes Christ along with him to work visit http://www.hiscpa.com/  and for his latest book Overcoming Life's 9/11's: Job's Journey and a Voice of One: Nehemiah's Prayer visit http://www.john-dillard.com/   (All Rights Reserved) Dare to Attempt Something so Great for the Kingdom of God that it is doomed to failure, lest Christ be in it! 

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About this blog
John Dillard, an author and Certified Public Accountant, serves HIM by serving you with his expertise in this blog... one tax return at a time!
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