Tuesday, January 31, 2017
Tuesday, January 24, 2017
Technical Advice Memorandums, colloquially called TAMs, are similar to PLRs but rear their ugly heads during the course of a proceeding before the IRS (including audits or before the IRS appeals division). A TAM may be requested by an IRS employee responsible for examining a taxpayer’s return (or a taxpayer may request that a particular issue be referred to the Chief Counsel’s Office for technical advice, which is an extremely powerful tool). A TAM may not be requested for hypothetical transactions. Additionally and like a PLR, TAMs cannot be cited for precedence.
Private Letter Rulings (colloquially called “PLRs”) are written statements from attorneys at the IRS Chief Counsel’s Office. In a nutshell PLRs are requested by taxpayers prior to undertaking a specific transaction, when the law is unclear (indeed).
PLRs are granted only with respect to proposed transactions or completed transactions for which a return has not yet been filed.
Mucho más importante, PLRs can only be relied upon by the party that requested the ruling.
Monday, January 23, 2017
Same day appointments are always available
Selig & Associates
Selig & Associates provides the most aggressive tax representation allowed by law. Specializing in payroll, income and sales tax controversies for individuals, contractors, restaurants and professional practices. Providing civil and criminal tax representation before the New York State Department of Taxation and Finance, the Department of Justice Tax Division and the Internal Revenue Service.
Our fees are Reasonable All tax representation is provided by a Federal Tax Practitioner and Licensed Attorney. To schedule a FREE face-to-face consultation, contact Selig & Associates today.
The IRS is testing expanded criteria for streamlined processing of taxpayer requests for installment agreements. The test is scheduled to run through September 30, 2017.
|Payment TermsUp to 72 months – or – the number of months necessary to satisfy the liability in full by the Collection Statute Expiration date, whichever is less||Payment TermsNone. This criteria is unchanged.|
|Collection Information StatementVerification of ability to pay required in event of an earlier default for assessed balances of $25,001 to $50,000||Collection Information StatementNot required.|
|Payment MethodDirect debit payments or payroll deduction required for assessed balances of $25,001 to $50,000||Payment MethodDirect debit payments or payroll deduction is preferred, but not required.|
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