Episode Summary: In this episode of Tax Problems Explained, host Leann Lyon is joined by Lawrence T. Ullmann, an attorney, CPA, and former IRS agent, to discuss the complexities surrounding the IRS's ability to reopen previously filed tax returns. Lawrence explains the general three-year statute of limitations for the IRS to examine returns, but highlights exceptions such as substantial omissions of income and fraudulent returns, which can extend the period to six years or indefinitely. The discussion also covers the differences between omitted income and fraudulent returns, and how the IRS approaches unreported income in older returns. Lawrence shares insights into how filing an amended return might prompt a closer look at prior years and offers practical advice for taxpayers concerned about older returns. Listeners gain valuable knowledge on how to navigate potential IRS inquiries and safeguard their financial records.

Key Timestamps: 00:01 – Introduction 00:20 – Overview of IRS Statutes of Limitations 01:10 – General Three-Year Rule Explained 02:08 – Exceptions for Substantial Omission of Income 02:42 – No Statute for Fraudulent Returns 03:05 – Difference Between Omission and Fraud 04:02 – IRS Review Processes for Older Returns 05:13 – Six-Year Statute for 25% Income Omission 06:12 – IRS Approach to Unreported Income 07:00 – Filing Amended Returns and IRS Scrutiny 08:04 – Case Example of IRS Reviewing Older Returns 09:15 – Misconceptions About IRS Limitations 10:46 – Steps to Address Concerns with Older Returns 11:31 – Importance of Maintaining Financial Records

About the Show: Tax Problems Explained is a podcast designed for individuals and businesses seeking clarity on complex tax issues. Hosted by seasoned professionals, including attorneys, CPAs, and former IRS agents, the show delves into the intricacies of the tax system, offering practical advice and insights. Each episode breaks down legal and financial concepts, making them accessible to listeners without a background in tax law. Whether dealing with audits, disputes, or planning, Tax Problems Explained provides valuable guidance to help navigate the often daunting world of taxation.

For more information, visit our website: https://www.lawrencetullmann.com/

Episode Summary: In this episode of Tax Problems Explained, host LeAnn Lyon is joined by Lawrence T. Ullmann, a seasoned attorney, CPA, and former IRS agent, to demystify the IRS bank levy process. Lawrence explains the circumstances under which the IRS can levy a taxpayer's bank account, detailing the steps leading up to this serious collection action. The discussion covers the importance of tax assessments, the series of notices sent to taxpayers, and the critical 30-day period to respond to a Notice of Intent to Levy.

Lawrence also shares insights into the 21-day freeze period on levied funds and offers practical advice on how taxpayers can potentially stop or reverse a levy, including situations involving joint accounts and hardship claims. This episode is essential for anyone facing IRS collection actions, providing listeners with actionable steps to protect their financial assets.

Key Timestamps: 00:01 – Introduction 0:35 – Understanding IRS Bank Levies 1:09 – Conditions for IRS to Levy Accounts 2:12 – Notice of Intent to Levy Explained 3:19 – Process of Freezing Bank Accounts 4:09 – Impact of a Levy on Account Funds 5:22 – Resolving Issues During the Freeze Period 6:57 – Strategies to Stop or Reverse a Levy 8:15 – Joint Accounts and Levy Implications 9:37 – Importance of Professional Representation 10:22 – Real-World Examples of Levy Resolutions 11:36 – Common Misconceptions About Protected Accounts 12:28 – Complexity of Business Accounts in Levies 13:23 – Steps to Take Before Funds Are Frozen

About the Show: Tax Problems Explained is a podcast designed for individuals and businesses seeking clarity on complex tax issues. Hosted by experts with decades of experience, the show breaks down intricate tax topics into understandable segments, offering practical advice and solutions. Whether you're dealing with IRS collections, audits, or general tax concerns, this series provides valuable insights and strategies to navigate the tax system effectively. With a focus on ethics and clarity, Tax Problems Explained aims to empower listeners with the knowledge needed to tackle their tax challenges confidently.

For more information, visit our website: https://www.lawrencetullmann.com/

Episode Summary:

In this episode of Tax Problems Explained, host LeAnn Lyon is joined by Lawrence T. Ullmann, a seasoned expert with decades of experience inside the IRS and private practice. Together, they delve into the complexities of the offer-in-compromise process, a formal IRS procedure to settle tax debt for less than what is owed. Lawrence explains the critical factors the IRS evaluates, such as a taxpayer's assets, future earnings, and compliance status. He highlights common pitfalls that lead to rejected applications and compares the offer-in-compromise with simpler options like IRS payment plans. Lawrence shares insights from real-life cases, emphasizing the importance of professional guidance in navigating this intricate process. Listeners will gain a deeper understanding of how to approach tax debt strategically and the potential benefits of pursuing an offer-in-compromise.

Key Timestamps: 00:01 – Introduction 00:54 – Understanding Offer-in-Compromise 01:59 – IRS Control in Negotiations 02:56 – Key Factors for IRS Evaluation 04:08 – Importance of Compliance 05:47 – Common Mistakes in Applications 06:43 – Offer-in-Compromise vs. Payment Plan 08:33 – Real-Life Case Example 10:06 – Consequences of Rejection 11:07 – Challenges Without Professional Help 12:48 – Assessing Offer-in-Compromise Viability 13:44 – Importance of Professional Guidance

About the Show:

Tax Problems Explained offers listeners a comprehensive look into the intricacies of the tax system from the perspectives of an attorney, a CPA, and a former IRS agent. Designed for individuals and businesses facing tax challenges, the series breaks down complex topics into understandable segments, providing valuable insights and practical solutions. With a focus on clarity and actionable advice, the show aims to empower listeners to tackle their tax issues with confidence and informed strategies.