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TOUGH IRS POLICIES ON REPEATER EMPLOYMENT TAX LIABILITIES
:
Repeater
Cases
The Internal Revenue Manual provides the following guidelines for negotiating with in-business repeaters:
"... if taxpayers:
• are in business,
• are currently pyramiding trust fund taxes, and
• have three or more trust fund bal dues assigned to the collection field function, then, they are considered "repeaters." These taxpayers may not -- immediately -- be granted installment agreements.
If, however, after contact, taxpayers originally classified as repeaters:
• do not continue to accrue liabilities; and,
• begin making FTDs; and,
• file all appropriate returns (so that they are in compliance with all
filing requirements); then, they are no longer considered repeaters and may
qualify for installment agreements." [IRM 5.14.7.2 ]
COPYRIGHT 2003 ROBERT E. MCKENZIE
Page created by: remckenzie@arnstein.com
Changes last made on:02/15/2003