Representing the Bankrupt Taxpayer
This unique publication combines two entirely separate fields of law - bankruptcy and tax - in a way that is accessible to anyone. The text reviews:
- The organization of the IRS and the Department of Justice with an emphasis on how bankruptcies are handled
- The IRS collection system
- Tax liens/levy and seizure
- Alternatives to bankruptcy
- Offers in compromise
- Automatic stay/adequate protection
- Pre-bankruptcy planning
- Discharge of taxes and penalties
- Bankruptcy for ongoing business and Chapter 11 proceedings
- Interest
- Cancellation of indebtedness and bad debts
- Taxation of individual and partnership bankruptcy estates
- Effect of bankruptcies on Net Operating Losses (NOLs) and credit carryforwards
- Real property dispositions in bankruptcy
There is a complete discussion of the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005.
Numerous examples make complex issues understandable.
Available from Thomson/West at 1-800-762-5272, or contact us directly.
This is the only book of its kind in the tax law. A thorough and understandable in-depth discussion of all the Internal Revenue Code Penalties and Interest. There is no other single source where both the practitioner and the individual can find out everything they need to know about IRS penalties and interest. There is an extensive discussion complete with examples in every chapter of:
- Accuracy Penalty
- Preparer penalties
- Trust Fund Recovery Penalty
- Delinquencies penalties
- Information return reporting requirements and penalties
- International transaction reporting requirements and penalties
- Reasonable cause and abatement of penalties
- Interest
- Various criminal tax penalties and how they interface with civil penalties
- Cash and currency reporting requirements and penalties
There are forms and instructions in every chapter.
Two looseleaf volumes updated annually.
Available from Thomson/West at 1-800-762-5272, or contact us directly.
Representation before the Appeals Division of the IRS
Use all the tactics available to reduce the tax liability and win your appeal.
By utilizing the Internal Revenue Manual and the author's own extensive experience, you get a comprehensive treatment of how to work with the Appeals Division of the IRS.
Appeals is now arguably the most important branch of the IRS. Not only does it handle appeals from audits and Tax Court cases, but virtually all collection due process (CDP), innocent spouse, and offers in compromise make their way to Appeals. Practitioners and taxpayers alike cannot afford not to know what happens in Appeals and how to win your case.
This workbook lays the groundwork for handling an appeal with important tools and tips to help you:
- Secure information and documents from the IRS regarding your client's case
- Use the Internal Revenue Manual to your best advantage and understand fully how the Appeals Division uses it
- Prepare a written protest and know when one is required
- Prepare strategies for an appeals conference
The Summary of Contents details how to create a successful appeal.
- Introduction
- IRS Organization and Appeals Function
- Qualifications to practice
- Tools of the Trade
- Audit process
- Securing Information and Documents from the IRS
- Choice of Forum
- When and why to protest
- Jurisdiction of Appeals
- Preparing Protest
- Preconference Preparation
- Conference
- Strategies - Statutes of Limitation and Innocent Spouse
- Settlement at Appeals
- Penalty Issues
- Partnership and Subchapter S Matters
- Special Programs at Appeals and Examination
- Statistics
- Attorney's Fees
Two looseleaf volumes updated annually.
Available from Thomson/West at 1-800-762-5272, or contact us directly.

