• Posts by Michael S. Raum
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    Mike focuses his practice on corporate and business transactions, working with clients at key points in the lifecycle of their businesses. His services range from company formation, structuring and exempt securities offerings to ...

Under IRC § 6330, a taxpayer is entitled to a “collection due process” (CDP) hearing before the IRS Appeals Office can take any enforced collection action.

One of the largest sources of stress for a taxpayer with significant federal tax debts is whether the IRS can take his or her house. For many taxpayers, the family residence is the most important source of their wealth. In addition, it is not just their house, but their home—a source of happiness and joy and family community. The prospect of losing a home therefore not only threatens financial loss, but it is often emotionally taxing as well.

A taxpayer with substantial back taxes has a few options to deal with IRS pressure to get them paid, and while an installment agreement can be a good outcome in some cases, there are many pitfalls to avoid when entering into one.
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