ROBERT E. MCKENZIE, ESQ.
ARNSTEIN & LEHR
120 SOUTH RIVERSIDE PLAZA, SUITE 1200 
CHICAGO, IL 60606
312-876-6927 
312-876-7318  fax 

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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

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Changes last made on:02/15/2003 

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