I need to get the assignment underway or my parents who died without a will may be in jeopardy of a tax lien sale.
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answered on Mar 8, 2024
To address delinquent property taxes and prevent a tax lien sale, especially in a situation involving inherited property from parents who passed away without a will, it's crucial to act quickly and efficiently. Crafting a letter to the homeowner, or in this case, to the relevant tax authority... View More 
My state allows Series LLC's. What would be the best structure to keep the assets under one LLC, and insulated from the other operating LLC?
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answered on Jan 22, 2024
Transferring assets from multiple LLCs to a single holding company can be a strategic move to consolidate assets and streamline operations. Since Montana allows Series LLCs, you might consider this structure. A Series LLC can have separate "cells" or "series," each with its own... View More
Concerning 28 USC 3001 et seq, after what amount of time is a quitclaim between one family member to another with no cost attached to it not able to be legally reversed or have a 3rd party lien placed against the property by the IRS?
answered on Feb 3, 2020
28 USC 3001(b) reverts to 26 USC 6503(a)(1) which contains a 10 year collection period that can be paused upon specific occurrences.
26 USC 6901 also has rules for extension of assessment under specific situations and allows collection of third party transfers form transferrees and... View More
I already know that if you do a quitclaim from one family member to another, without charging them money for it, while there is currently no lien on the house Just to file bankruptcy that the quitclaim is going to end up getting reversed by a judge. However, I have been told by a lawyer outside of... View More
Can the I.R.S. legally find a way to reverse a quitclaim on the title to a person’s house if it was quitclaimed over from a mother to her child, who are still living together in the same house, before neither a lien nor a levy could end up being put on the property?
answered on Feb 1, 2020
Yes, there's state and federal laws that reverse fraudulent teanfers or create third party liens where property was transferred for less than fair market value or in an attempt to defraud creditors.
left his wife with a lot of tax debt that he lied to his wife about by saying he had paid it all off already, like 20 years ago, but really he just kept filing offer and compromise and bankruptcy but never went through with it anytime he did it and so the statute of limitations just kept pausing... View More
answered on Dec 11, 2019
If you tried innocent spouse and do not have any appeals rights then the only thing that you can do is set up a collection alternative with the IRS. You need the assistance of a good tax lawyer. Most of us offer a free consultation and after speaking with you can offer you advice based on your... View More
Even though my tax debt is older than 10 years the statute of limitations was paused by the IRS for unknown reasons.
answered on Oct 28, 2019
You'd have to review all transcript over the entirety of the period for which the amounts were owed to pull out the transaction codes to see where and why the CSED was paused.
I know that trying an offer and compromise and innocent spouse pauses the 10 year statute of limitations. However, what are all of the things that are going to pause the 10 year statute of limitations? Thank you.
answered on Oct 27, 2019
Requesting transcripts does not pause the collection statute expiration Date (CSED).
For more information I would look at the Internal Revenue Manual 5.1.19
https://www.irs.gov/irm/part5/irm_05-001-019
I received an IRS notice for penalties and interest for late filing of 2015 and 2016 corporate tax returns for a Montana close corporation. They incorrectly identified 2 shareholders so I wrote a letter explaining: there was 1 shareholder; I had erroneously been told by what I thought was a valid... View More
answered on Jan 24, 2018
It sounds like you were charged a failure to file penalty. Sometimes the IRS will abate the penalties once you have filed the required returns. I suggest filing a penalty abatement request. If that does not bring the debt down to an amount you can afford then you can try and submit an Offer in... View More
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