Re: 90-Day Letter: Whether to Sign Waiver

Robt wrote:
Greetings!

We have a client who got a 90-day letter, which runs out next week.

We understand the procedural consequences of failing to file a petition in
Tax Court: assessment, immediate forcible collection, no court review
unless assessment paid and suit filed for a refund.

The client simply never filed a return for his 2000 TY. The IRS's assessed
amount is easily $100,000 out of line. Client is traveling in another
state, and he doesn't have access to his records.

He's a wonderful guy -- his failure to file is the result of a multitude
of family tragedies. Until now, he just didn't have the psychological
energy to address his tax mess.

We're thinking to prepare a return as best we can, contact the IRS and
offer immediate payment, but decline to sign the waiver. Then, we would
file in Tax Court and be prepared to litigate the question of his actual
tax liability.

Is there a better strategy? Would we get whacked with sanctions by the Tax
Court? Should we be giving any thought to signing the waiver? Is there a
better strategy?

Thanks to you all!



Don't sign no waiver!

Tim
http://www.nontaxpayer.net/problems.html
.

Relevant Pages

  • Re: 90-Day Letter: Whether to Sign Waiver
    ... We have a client who got a 90-day letter, ... Tax Court: assessment, immediate forcible collection, no court review ... but decline to sign the waiver. ...
    (misc.taxes)
  • 90-Day Letter: Whether to Sign Waiver
    ... We have a client who got a 90-day letter, ... Tax Court: assessment, immediate forcible collection, no court review ...
    (misc.taxes)
  • Re: Kent Hovind - Subornation of False Muster?
    ... Kent Hovind's civil U.S. Tax Court case was won by ... was the civil liabilities that brought down the Dixons and the IBT. ... long to get this far with Hovind. ...
    (talk.origins)
  • Re: Camerons Unemployment Knowledge
    ... For the normal taxpayer, it will be the tax allowances ... "Parts of Britain are now almost wholly dependent on the state. ... you may follow up more if you care....look under 'client state' etc ... more for sickness than unemployment, more if you are a lone parent or ...
    (uk.politics.misc)
  • Re: Do DIRECT TAXES still require APPORTIONMENT?
    ... > REC-ATT, 31 CFR §10.34, Standards for advising with respect to tax return ... > positions and for preparing or signing returns.-- ... > return as a preparer if the practitioner determines that the tax return ... A practitioner may not advise a client to take a position ...
    (misc.taxes)
Loading