National Back Taxes & IRS Debt Resolution — Enrolled Agent, All 50 States

What we actually do

We are a small, focused tax practice. The principal is an Enrolled Agent (EA) — a federally licensed tax practitioner authorized by the U.S. Department of the Treasury under Circular 230 to represent taxpayers before the Internal Revenue Service in examination, collection, and appeals matters, in every U.S. state and territory. EA practice rights are granted by federal law, not state license, which is why a virtual EA practice can legitimately serve clients nationwide.

We work IRS collection cases end-to-end: pulling account and wage-and-income transcripts, mapping Collection Statute Expiration Dates (CSEDs), preparing unfiled returns, and negotiating resolution under the IRS Collection Financial Standards. We do not run a call center. We do not promise settlements before we have seen your transcripts.

Resolution paths for IRS back taxes

1. Unfiled returns — the prerequisite

No collection alternative — no Offer in Compromise, no installment agreement, no Currently Not Collectible determination — is available to a taxpayer who is not in filing compliance. The IRS will not negotiate with a non-filer. The first step in almost every back-tax case is preparing the missing federal (and, where relevant, state) returns, often reconstructed from IRS wage-and-income transcripts (Form W-2, 1099, K-1, 1098, and 5498 data the IRS already holds) supplemented by client records.

For most taxpayers the IRS expects the last six years of returns to be filed to be considered current under the standard Policy Statement 5-133 administrative practice. Older years can sometimes be left unfiled where the IRS has already substitute-for-return assessed them and the CSED is short.

2. Offer in Compromise (Form 656)

An Offer in Compromise (OIC) is the program most associated with "settling for less." The dominant basis is Doubt as to Collectibility: the IRS accepts an offer amount equal to the taxpayer's reasonable collection potential (RCP), which is the sum of net realizable equity in assets plus a multiplier of monthly disposable income.

• The offer is submitted on Form 656 with Form 433-A (OIC) for individuals or Form 433-B (OIC) for businesses.
• An application fee and an initial offer payment are required unless the Low-Income Certification applies.
• The IRS allowable living expenses are governed by the Collection Financial Standards (national standards for food/clothing, out-of-pocket healthcare; local standards for housing and transportation).
• All required returns must be filed and current-year withholding or estimated payments must be on track.
• If the IRS rejects the offer, an appeal is available within 30 days.

The OIC is the right tool when the math works. It is the wrong tool — and an expensive one — when RCP exceeds the liability or when a partial-pay installment agreement would produce the same economic result with less friction. This is what diligent transcript work and an honest 433 analysis determine before filing an offer.

3. Installment Agreements (Form 9465)

The IRS administers several installment agreement (IA) tiers, each with different documentation burdens:

• Guaranteed IA — assessed balance at or below the statutory threshold, 36-month payoff, no financial disclosure.
• Streamlined IA — assessed balance at or below the published streamlined threshold (currently $50,000 for individuals, $25,000 for in-business sole proprietors and businesses with employment tax liabilities, at the time of writing), full payoff within 72 months or by CSED, no Form 433 required.
• Non-streamlined IA — above the streamlined threshold; Form 433-F or 433-A financial disclosure; payment must full-pay by CSED.
• Partial-pay IA (PPIA) — full pay is impossible within the remaining CSED; the IRS accepts what the financial analysis supports; two-year financial reviews are standard.

IAs are requested on Form 9465 (individuals) or through the IRS Online Payment Agreement portal. Setup fees vary by payment method and income level; direct-debit IAs have the lowest setup fee and the best long-term reliability.

4. Currently Not Collectible (CNC) — Status 53

If a Form 433 financial analysis shows that IRS-allowed necessary living expenses meet or exceed gross monthly income, the IRS will move the account to Currently Not Collectible (internally Status 53). Active collection — levies, garnishments, collection calls — stops. Notice of Federal Tax Lien may still be filed. Penalties and interest continue. The CSED continues to run, which means a CNC placement can quietly age a debt to expiration without a dollar paid.

CNC is reviewed against income flags; if income later rises above thresholds, the account is reactivated. It is an underused, undramatic, often-correct answer for low-income taxpayers and seniors on fixed income.

5. Penalty Abatement

Two operative regimes:

• First-Time Abate (FTA) — administrative waiver of failure-to-file, failure-to-pay, and failure-to-deposit penalties for one tax period if there is a clean three-year compliance history and current-period compliance.
• Reasonable Cause — facts-and-circumstances waiver where ordinary business care and prudence were exercised; serious illness, unavoidable absence, casualty, records destruction, and (in narrow situations) reliance on a tax professional are the canonical grounds.

FTA is checked first because it is administrative and uses no reasonable-cause "credit." Estimated tax penalties (IRC § 6654/6655) are not eligible for FTA and follow their own waiver rules.

6. Trust Fund Recovery Penalty (TFRP) defense

Business owners, officers, bookkeepers, and check-signers can be assessed personally for unpaid employment trust fund taxes under IRC § 6672. The IRS conducts the investigation through a Form 4180 interview. The TFRP pierces corporate and LLC liability protection. We help with the Form 4180 record, responsible-person and willfulness analysis, protest and appeal of proposed assessments, and resolution of assessed TFRPs.

7. Levy & lien release

Levies (wage, bank, accounts receivable) are released under IRC § 6343 when one of the statutory grounds is met — economic hardship, established installment agreement, pending OIC, statute expiration, or release facilitating collection. Bank levies have a 21-day hold before the bank remits to the IRS; that window is the difference between a release and a loss.

A Notice of Federal Tax Lien (NFTL) is a public claim against property. Beyond pay-and-release, the IRS recognizes withdrawal (return to pre-filing position), subordination (allow another creditor priority to enable refinance), and discharge (release of a specific property). Each is its own form and its own argument.

8. Audit and examination representation

Federal income tax examination representation under Form 2848 Power of Attorney — correspondence audits, office audits, and field audits. We handle the entire interaction with the examiner so the taxpayer does not have to.

How we work a case

1. Engagement & Form 2848. One email exchange to confirm scope. We file Power of Attorney with the IRS Centralized Authorization File (CAF).
2. Transcript pull. Account transcripts, wage-and-income transcripts, and record-of-account for every year at issue. We map the CSED for each assessed period.
3. Compliance. Missing returns prepared. Current-year withholding or estimated payments verified.
4. Financial analysis. Form 433-F or 433-A built against IRS Collection Financial Standards. The numbers determine the right resolution path.
5. Resolution. OIC, IA, PPIA, or CNC filed. Penalty abatement layered where applicable.
6. Monitor. CSED tracking, levy-trigger watch, and compliance through resolution.

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