Chamberlain, Hrdlicka, White, Williams & Martin

Dear Colleagues, Clients, and Friends:

     I am attaching my article entitled "No Returns, No Problem: Tax Court Rules in Case of First Impression that IRS Must Consider Economic Hardship in Pre-Levy CDP Cases." It was recently published in the Journal of Tax Practice & Procedure.

     Click here to read the article.

     As the economy continues to struggle, many people are unable meet their basic needs, much less pay their federal taxes on time. Therefore, requests for "collection alternatives," such as offers-in-compromise and installment agreements, are on the rise. The IRS's longstanding policy has been to reject at the outset any proposed collection alternative from a taxpayer who is not current with all federal tax filing requirements. However, the Tax Court recently issued a taxpayer-friendly decision, Vinatieri v. Commissioner, which arguably eradicates this IRS policy in certain situations. The attached article examines the case and its potential implications for taxpayers.

     If you have questions about the article, please call me at (404) 658-5441.

Regards,

Hale

Hale E. Sheppard, Esq.
Chamberlain, Hrdlicka, White, Williams & Martin
191 Peachtree Street, N.E.
34th Floor
Atlanta, Georgia 30303
Phone: (404) 658-5441
Fax: (404) 658-5541
E-mail: hale.sheppard@chamberlainlaw.com
Website: www.chamberlainlaw.com/attorneys-96.html