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  #8  
Old 03-08-2005, 09:56 AM
Harlan Lunsford
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Default Re: Sticky wicket, re 941 taxes owed

rulon wrote:

- quote -

> First... a LARGE retainer up front. Council on closing or
> selling business. Can this be a viable operation if the
> current taxes cannot be paid??


When I see you in late May, Paul, I'll lgive you more
perspective if you want it. And if you buy me a drink, the
story will get even more juicy.

Closing the business however is not an option, for this is
the only thing he knows.

Hmmm... maybe.... if we (he) incorporates under another name
next year , and..... (let your mind run with this one!
grin)

ChEAr$,
Harlan Lunsford, EA n LA
Mon 7 mar 2005

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #7  
Old 03-08-2005, 09:56 AM
Harlan Lunsford
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Posts: n/a
Default Re: Sticky wicket, re 941 taxes owed

TaxmanHog wrote:
- quote -

> "Harlan Lunsford" wrote...
> > > TaxmanHog wrote:


> > > If a fresh face is assigned to the case, a thorough initial
> > > investigation of ICS case history, via officer compliance
> > > check & review will yield plenty of information for the
> > > ~fresh~ minded R/O to develop a biased "Here we go again
> > > attitude".


> > Thanks, TMH; I really appreciate your thoughts, just as Phil
> > predicted (see above).
> > > I'm wondering right now though, is there some magical

> > threshold amount , say.. 25,000$, that determines when the
> > case gets sent for "personal" review? We're talking here
> > about three quarters of 941 taxes of about 53K$ you know.
> > How long do you reckon we (I mean "he") can keep on sending
> > in 1000 or so at a time?
> > > But when the case DOES come down , and push comes to shove,

> > and IF that same RO gets the case (shudder!) I can hear
> > her now: "WhAT? that white boy again?" Talk about bias.


> Have him continue to send in the part-pays on the older
> periods, and -STAY- current with depositing from this point
> forward!!!!, ACS will not be able to handle the TFRP issue,
> and will queue the case for delivery to the field as soon as
> practical
> I suspect it will not take too long, Trust Fund taxes on
> recent periods will give it a HIGH risk score, (modernized
> version of RWMS score you might recall from the 'ol days).
> These risk levels are dynamic, specific to each group's work
> load capacity and cases in the queue for it's geographic
> area.
> I hope that's not the type of attitude this RO truly has!


Last first. I certainly hope it's not the kind of attitude
she has also. But we'll see.

Thanks so much for your comments, TMHog. They are really so
much appreciated. In the back of my mind I kinda thought
it might depend on geography, so from past experience I have
hope that we... uh... he .. (client) has some more time.

ChEAr$,
Harlan Lunsford, EA n LA
Mon 7 mar 2005

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #6  
Old 03-07-2005, 10:07 AM
rulon
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Posts: n/a
Default Re: Sticky wicket, re 941 taxes owed

First... a LARGE retainer up front. Council on closing or
selling business. Can this be a viable operation if the
current taxes cannot be paid??

Paul Woodward

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #5  
Old 03-07-2005, 07:53 AM
TaxmanHog
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Posts: n/a
Default Re: Sticky wicket, re 941 taxes owed

"Harlan Lunsford" wrote...
- quote -

> > TaxmanHog wrote:

> > If a fresh face is assigned to the case, a thorough initial
> > investigation of ICS case history, via officer compliance
> > check & review will yield plenty of information for the
> > ~fresh~ minded R/O to develop a biased "Here we go again
> > attitude".


> Thanks, TMH; I really appreciate your thoughts, just as Phil
> predicted (see above).
> I'm wondering right now though, is there some magical
> threshold amount , say.. 25,000$, that determines when the
> case gets sent for "personal" review? We're talking here
> about three quarters of 941 taxes of about 53K$ you know.
> How long do you reckon we (I mean "he") can keep on sending
> in 1000 or so at a time?
> But when the case DOES come down , and push comes to shove,
> and IF that same RO gets the case (shudder!) I can hear
> her now: "WhAT? that white boy again?" Talk about bias.


Have him continue to send in the part-pays on the older
periods, and -STAY- current with depositing from this point
forward!!!!, ACS will not be able to handle the TFRP issue,
and will queue the case for delivery to the field as soon as
practical

I suspect it will not take too long, Trust Fund taxes on
recent periods will give it a HIGH risk score, (modernized
version of RWMS score you might recall from the 'ol days).

These risk levels are dynamic, specific to each group's work
load capacity and cases in the queue for it's geographic
area.

I hope that's not the type of attitude this RO truly has!

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #4  
Old 03-03-2005, 06:49 AM
Rick Merrill
Guest
 
Posts: n/a
Default Re: Sticky wicket, re 941 taxes owed

Harlan Lunsford wrote:

- quote -

> Client is fulfilling an agreement re 941, 940 and 1040 taxes
> resulting from schedule c business in past years. After
> all, 900$ per month ain't bad.
> After this agreement became effective, he (we) reactivated
> his previous corporation to take over the business.
> Everything fine first quarter of 2004, but... well... he
> got behind again. (bad boy!) But of course these 941
> taxes are corporate in nature (1120S if that makes any
> difference). We're talking about total of about 53,000$
> worth, more or less for the last three quarters of 2004.
> It looks then like he's on the last strike (2 out of three
> already).
> So far he (we) have just gotten bills from IRS and to each
> one he sends in a thousand or two. What I'm concerned
> about is that IF the same revenue officer happens to get the
> case she will say to herself; WHAT? that fellow AGAIN? And
> come down hard.
> What would YOU do?


Do you mean what would I do as the IRS officer ?-) or as
you the advisor ?-) or as the client ?-(

I know a guy who lost his house to the IRS over just such a
problem!

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #3  
Old 03-03-2005, 05:52 AM
Harlan Lunsford
Guest
 
Posts: n/a
Default Re: Sticky wicket, re 941 taxes owed

TaxmanHog wrote:
- quote -

> "Harlan Lunsford" <> wrote.....

> > Here's the situation.
> > > Client is fulfilling an agreement re 941, 940 and 1040 taxes

> > resulting from schedule c business in past years. After
> > all, 900$ per month ain't bad.
> > > After this agreement became effective, he (we) reactivated

> > his previous corporation to take over the business.
> > Everything fine first quarter of 2004, but... well... he
> > got behind again. (bad boy!) But of course these 941
> > taxes are corporate in nature (1120S if that makes any
> > difference). We're talking about total of about 53,000$
> > worth, more or less for the last three quarters of 2004.
> > > It looks then like he's on the last strike (2 out of three

> > already).
> > > So far he (we) have just gotten bills from IRS and to each

> > one he sends in a thousand or two. What I'm concerned
> > about is that IF the same revenue officer happens to get the
> > case she will say to herself; WHAT? that fellow AGAIN? And
> > come down hard.


> Most likely, the case will flow out to the same Revenue
> Officer Group, who receives the case is a luck of the draw
> it this point, the GM's do scan the incoming QUEUE, if they
> are quick witted, might see the connection between the Sole
> Proprietor case and the Corporation Case, this is not always
> clear at the out set. Grade level of the case 9/11/12, and
> RO case load levels the day the GM is deciding who gets what
> will be the driving factor.
> Since they involve the same ~Principal~ actor, "Very Bad
> Boy.... Indeed", the GM might assign the case to the same
> R/O, OTOH, might not.
> If a fresh face is assigned to the case, a thorough initial
> investigation of ICS case history, via officer compliance
> check & review will yield plenty of information for the
> ~fresh~ minded R/O to develop a biased "Here we go again
> attitude".
> Been there, done that.


Thanks, TMH; I really appreciate your thoughts, just as Phil
predicted (see above).

I'm wondering right now though, is there some magical
threshold amount , say.. 25,000$, that determines when the
case gets sent for "personal" review? We're talking here
about three quarters of 941 taxes of about 53K$ you know.
How long do you reckon we (I mean "he") can keep on sending
in 1000 or so at a time?

But when the case DOES come down , and push comes to shove,
and IF that same RO gets the case (shudder!) I can hear
her now: "WhAT? that white boy again?" Talk about bias.

ChEAr$,
Harlan Lunsford, EA n LA
Mon 28 Feb 2005

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #2  
Old 03-03-2005, 05:52 AM
Harlan Lunsford
Guest
 
Posts: n/a
Default Re: Sticky wicket, re 941 taxes owed

Phil Marti wrote:
- quote -

> "Harlan Lunsford" <hlunsford[at]bellsouth.net> wrote:

> > Here's the situation.
> > > Client is fulfilling an agreement re 941, 940 and 1040 taxes

> > resulting from schedule c business in past years. After
> > all, 900$ per month ain't bad.
> > > After this agreement became effective, he (we) reactivated

> > his previous corporation to take over the business.
> > Everything fine first quarter of 2004, but... well... he
> > got behind again. (bad boy!) But of course these 941
> > taxes are corporate in nature (1120S if that makes any
> > difference). We're talking about total of about 53,000$
> > worth, more or less for the last three quarters of 2004.
> > > It looks then like he's on the last strike (2 out of three

> > already).
> > > So far he (we) have just gotten bills from IRS and to each

> > one he sends in a thousand or two. What I'm concerned
> > about is that IF the same revenue officer happens to get the
> > case she will say to herself; WHAT? that fellow AGAIN? And
> > come down hard.
> > > What would YOU do?


> Hopefully Taxman Hog will come along with current thoughts,
> but I suggest you pray. In my day I'd have seized
> everything I could find before God got the news.


Oh boy, speak of the devil! Just read your reply, which
is first, and notice that Taxman Hog's reply is next. I'm
replying to you first, before reading his. I can HARDly
wait!

Stay tuned.

ChEAr$,
Harlan Lunsford, EA n LA
Mon 28 Feb 2005

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #1  
Old 02-28-2005, 06:19 PM
TaxmanHog
Guest
 
Posts: n/a
Default Re: Sticky wicket, re 941 taxes owed

"Harlan Lunsford" <> wrote.....

- quote -

> Here's the situation.
> Client is fulfilling an agreement re 941, 940 and 1040 taxes
> resulting from schedule c business in past years. After
> all, 900$ per month ain't bad.
> After this agreement became effective, he (we) reactivated
> his previous corporation to take over the business.
> Everything fine first quarter of 2004, but... well... he
> got behind again. (bad boy!) But of course these 941
> taxes are corporate in nature (1120S if that makes any
> difference). We're talking about total of about 53,000$
> worth, more or less for the last three quarters of 2004.
> It looks then like he's on the last strike (2 out of three
> already).
> So far he (we) have just gotten bills from IRS and to each
> one he sends in a thousand or two. What I'm concerned
> about is that IF the same revenue officer happens to get the
> case she will say to herself; WHAT? that fellow AGAIN? And
> come down hard.


Most likely, the case will flow out to the same Revenue
Officer Group, who receives the case is a luck of the draw
it this point, the GM's do scan the incoming QUEUE, if they
are quick witted, might see the connection between the Sole
Proprietor case and the Corporation Case, this is not always
clear at the out set. Grade level of the case 9/11/12, and
RO case load levels the day the GM is deciding who gets what
will be the driving factor.

Since they involve the same ~Principal~ actor, "Very Bad
Boy.... Indeed", the GM might assign the case to the same
R/O, OTOH, might not.

If a fresh face is assigned to the case, a thorough initial
investigation of ICS case history, via officer compliance
check & review will yield plenty of information for the
~fresh~ minded R/O to develop a biased "Here we go again
attitude".

Been there, done that.

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
 
Old 02-28-2005, 05:40 PM
Phil Marti
Guest
 
Posts: n/a
Default Re: Sticky wicket, re 941 taxes owed

"Harlan Lunsford" <hlunsford[at]bellsouth.net> wrote:

- quote -

> Here's the situation.
> Client is fulfilling an agreement re 941, 940 and 1040 taxes
> resulting from schedule c business in past years. After
> all, 900$ per month ain't bad.
> After this agreement became effective, he (we) reactivated
> his previous corporation to take over the business.
> Everything fine first quarter of 2004, but... well... he
> got behind again. (bad boy!) But of course these 941
> taxes are corporate in nature (1120S if that makes any
> difference). We're talking about total of about 53,000$
> worth, more or less for the last three quarters of 2004.
> It looks then like he's on the last strike (2 out of three
> already).
> So far he (we) have just gotten bills from IRS and to each
> one he sends in a thousand or two. What I'm concerned
> about is that IF the same revenue officer happens to get the
> case she will say to herself; WHAT? that fellow AGAIN? And
> come down hard.
> What would YOU do?


Hopefully Taxman Hog will come along with current thoughts,
but I suggest you pray. In my day I'd have seized
everything I could find before God got the news.

--
Phil Marti
Clarksburg, MD

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
  #-1  
Old 02-27-2005, 01:34 PM
Harlan Lunsford
Guest
 
Posts: n/a
Default Sticky wicket, re 941 taxes owed

Here's the situation.

Client is fulfilling an agreement re 941, 940 and 1040 taxes
resulting from schedule c business in past years. After
all, 900$ per month ain't bad.

After this agreement became effective, he (we) reactivated
his previous corporation to take over the business.
Everything fine first quarter of 2004, but... well... he
got behind again. (bad boy!) But of course these 941
taxes are corporate in nature (1120S if that makes any
difference). We're talking about total of about 53,000$
worth, more or less for the last three quarters of 2004.

It looks then like he's on the last strike (2 out of three
already).

So far he (we) have just gotten bills from IRS and to each
one he sends in a thousand or two. What I'm concerned
about is that IF the same revenue officer happens to get the
case she will say to herself; WHAT? that fellow AGAIN? And
come down hard.

What would YOU do?

ChEAr$,
Harlan Lunsford, EA n LA

<< -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << ------------------------------------------------->
 

Tags
941, owed, sticky, taxes, wicket
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