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Offer in Compromise
FYI
The limitations period refers to the limitation of the 2,3,240 rule. No
one mentioned the SOL
which was never defined either.
r
In a message dated 6/12/2013 12:27:53 A.M. Pacific Daylight Time,
cdcbaamailbox@gmail.com writes:
if you calculate a limitations period to file a bk against the irs, you will be S O L (something out of luck) Stick with the 3 year, 2 year and 240
day rules, they apply, SOL does not apply.
d
On Jun 2, 2013, at 1:46 PM, _robert90701@aol.com_
(mailto:robert90701@aol.com) wrote:
Dear Paul:
There needs to be a calculation in the file computing when the Limitationsperiod expired.
It looks like it did not expire. There should be correspondence from theIRS stating when
the OIC was breached. I don't know if a transcript would show it but it
is worth a try.
Keep us informed.
SYs
Robert Suhajda
In a message dated 6/2/2013 12:33:49 P.M. Pacific Daylight Time,
_attorneypaul2000@yahoo.com_ (mailto:attorneypaul2000@yahoo.com) writes:
The assessment was in 11/1/2010. The offer in compromise was filed in
12/1/10 and was accepted and approved in August 2011. PC made one payment for
the OIC in August 2011 and never made another payment. So has the OIC in
default or is it still in effect?
If the OIC is still in effect does it toll the 240 + 30 days? If not in
effect then it has been more than 270 days since August 2011.
Paul Horn
Attorney at Law
Certified Public Accountant
850 E. Las Tunas Drive
San Gabriel, CA 91776
800-380-7076
____________________________________
To: _cdcbaa@yahoogroups.com_ (mailto:cdcbaa@yahoogroups.com)
Sent: Saturday, June 1, 2013 8:14 PM
Subject: Re: [cdcbaa] Offer in Compromise
Hello Paul:
Yes, it is too close to rely on a guesstimate. The SOL date has to be
calculated exactly. Tell
me how long the SOL was tolled exactly.
Sincerely yours,
Robert Suhajda, MS, CPA,
Robert Suhajda,
Business and Tax Consultant
In a message dated 6/1/2013 5:05:04 P.M. Pacific Daylight Time,
_attorneypaul2000@yahoo.com_ (mailto:attorneypaul2000@yahoo.com) writes:
PC owes federal income taxes from year 2007. 2007 tax return was filed
on 11/1/2010. The offer in compromise was approved on August 2011. PC madeonly one payment toward the offer in compromise since August 2011. Issue: Is
the OIC consider in effect to prevent the chapter 7?
The post was migrated from Yahoo.
if you calculate a limitations period to file a bk against the irs, you will be S O L (something out of luck) Stick with the 3 year, 2 year and 240 day rules, they apply, SOL does not apply.
d
On Jun 2, 2013, at 1:46 PM, robert90701@aol.com wrote:
> Dear Paul:
>
> There needs to be a calculation in the file computing when the Limitations period expired.
> It looks like it did not expire. There should be correspondence from the IRS stating when
> the OIC was breached. I don't know if a transcript would show it but it is worth a try.
>
> Keep us informed.
>
> SYs
>
> Robert Suhajda
>
> In a message dated 6/2/2013 12:33:49 P.M. Pacific Daylight Time, attorneypaul2000@yahoo.com writes:
>
> The assessment was in 11/1/2010. The offer in compromise was filed in 12/1/10 and was accepted and approved in August 2011. PC made one payment for the OIC in August 2011 and never made another payment. So has the OIC in default or is it still in effect?
>
> If the OIC is still in effect does it toll the 240 + 30 days? If not in effect then it has been more than 270 days since August 2011.
>
> Paul Horn
> Attorney at Law
> Certified Public Accountant
> 850 E. Las Tunas Drive
> San Gabriel, CA 91776
> 800-380-7076
>
>
> To: cdcbaa@yahoogroups.com
> Sent: Saturday, June 1, 2013 8:14 PM
> Subject: Re: [cdcbaa] Offer in Compromise
>
>
> Hello Paul:
>
> Yes, it is too close to rely on a guesstimate. The SOL date has to be calculated exactly. Tell
> me how long the SOL was tolled exactly.
>
> Sincerely yours,
>
> Robert Suhajda, MS, CPA,
>
> Robert Suhajda,
>
> Business and Tax Consultant
>
>
>
>
> In a message dated 6/1/2013 5:05:04 P.M. Pacific Daylight Time, attorneypaul2000@yahoo.com writes:
>
> PC owes federal income taxes from year 2007. 2007 tax return was filed on 11/1/2010. The offer in compromise was approved on August 2011. PC made only one payment toward the offer in compromise since August 2011. Issue: Is the OIC consider in effect to prevent the chapter 7?
>
> From my analysis they satisfied the 3 years, 2 years and 240 days rules. If these 3 time rules are satisfied, do I have to worry about tolling of the OIC still being in effect? Is the OIC considered in effect>
> Thanks
>
> Paul Horn
> Attorney at Law
> Certified Public Accountant
> 850 E. Las Tunas Drive
> San Gabriel, CA 91776
> 800-380-7076
>
>
>
>
>
The post was migrated from Yahoo.
sol has nothing to do with the calculation of the date you can file a bk. Sol is 10 years. 2 year and three year rules are not statutes of limitations. Irs can collect for much longer.
d
Sent from my fingers
On Jun 2, 2013, at 1:46 PM, robert90701@aol.com wrote:
> Dear Paul:
>
> There needs to be a calculation in the file computing when the Limitations period expired.
> It looks like it did not expire. There should be correspondence from the IRS stating when
> the OIC was breached. I don't know if a transcript would show it but it is worth a try.
>
> Keep us informed.
>
> SYs
>
> Robert Suhajda
>
> In a message dated 6/2/2013 12:33:49 P.M. Pacific Daylight Time, attorneypaul2000@yahoo.com writes:
>
> The assessment was in 11/1/2010. The offer in compromise was filed in 12/1/10 and was accepted and approved in August 2011. PC made one payment for the OIC in August 2011 and never made another payment. So has the OIC in default or is it still in effect?
>
> If the OIC is still in effect does it toll the 240 + 30 days? If not in effect then it has been more than 270 days since August 2011.
>
> Paul Horn
> Attorney at Law
> Certified Public Accountant
> 850 E. Las Tunas Drive
> San Gabriel, CA 91776
> 800-380-7076
>
>
> To: cdcbaa@yahoogroups.com
> Sent: Saturday, June 1, 2013 8:14 PM
> Subject: Re: [cdcbaa] Offer in Compromise
>
>
> Hello Paul:
>
> Yes, it is too close to rely on a guesstimate. The SOL date has to be calculated exactly. Tell
> me how long the SOL was tolled exactly.
>
> Sincerely yours,
>
> Robert Suhajda, MS, CPA,
>
> Robert Suhajda,
>
> Business and Tax Consultant
>
>
>
>
> In a message dated 6/1/2013 5:05:04 P.M. Pacific Daylight Time, attorneypaul2000@yahoo.com writes:
>
> PC owes federal income taxes from year 2007. 2007 tax return was filed on 11/1/2010. The offer in compromise was approved on August 2011. PC made only one payment toward the offer in compromise since August 2011. Issue: Is the OIC consider in effect to prevent the chapter 7?
>
> From my analysis they satisfied the 3 years, 2 years and 240 days rules. If these 3 time rules are satisfied, do I have to worry about tolling of the OIC still being in effect? Is the OIC considered in effect>
> Thanks
>
> Paul Horn
> Attorney at Law
> Certified Public Accountant
> 850 E. Las Tunas Drive
> San Gabriel, CA 91776
> 800-380-7076
>
>
>
>
>
The post was migrated from Yahoo.
Dear Paul:
There needs to be a calculation in the file computing when the Limitations period expired.
It looks like it did not expire. There should be correspondence from theIRS stating when
the OIC was breached. I don't know if a transcript would show it but it
is worth a try.
Keep us informed.
SYs
Robert Suhajda
In a message dated 6/2/2013 12:33:49 P.M. Pacific Daylight Time,
attorneypaul2000@yahoo.com writes:
The assessment was in 11/1/2010. The offer in compromise was filed in
12/1/10 and was accepted and approved in August 2011. PC made one payment for
the OIC in August 2011 and never made another payment. So has the OIC in
default or is it still in effect?
If the OIC is still in effect does it toll the 240 + 30 days? If not in
effect then it has been more than 270 days since August 2011.
Paul Horn
Attorney at Law
Certified Public Accountant
850 E. Las Tunas Drive
San Gabriel, CA 91776
800-380-7076
____________________________________
To: cdcbaa@yahoogroups.com
Sent: Saturday, June 1, 2013 8:14 PM
Subject: Re: [cdcbaa] Offer in Compromise
Hello Paul:
Yes, it is too close to rely on a guesstimate. The SOL date has to be
calculated exactly. Tell
me how long the SOL was tolled exactly.
Sincerely yours,
Robert Suhajda, MS, CPA,
Robert Suhajda,
Business and Tax Consultant
In a message dated 6/1/2013 5:05:04 P.M. Pacific Daylight Time,
attorneypaul2000@yahoo.com writes:
PC owes federal income taxes from year 2007. 2007 tax return was filed
on 11/1/2010. The offer in compromise was approved on August 2011. PC madeonly one payment toward the offer in compromise since August 2011. Issue: Is
the OIC consider in effect to prevent the chapter 7?
The post was migrated from Yahoo.
The assessment was in 11/1/2010. The offer in compromise was
filed in 12/1/10 and was accepted and approved in August 2011. PC made one
payment for the OIC in August 2011 and never made another payment. So has the
OIC in default or is it still in effect?
If the OIC is still in effect does it toll the 240 + 30
days? If not in effect then it has been more than 270 days since August 2011.
Paul Horn
Attorney at Law
Certified Public Accountant
850 E. Las Tunas Drive
San Gabriel, CA 91776
800-380-7076
________________________________
To: cdcbaa@yahoogroups.com
Sent: Saturday, June 1, 2013 8:14 PM
Subject: Re: [cdcbaa] Offer in Compromise
Hello Paul:
Yes, it is too close to rely on a guesstimate.TheSOL datehas to be calculated exactly.Tell
me how long theSOL was tolled exactly.
Sincerely
yours,
Robert Suhajda, MS, CPA,
Robert Suhajda,
Business and
Tax Consultant
In a message dated 6/1/2013 5:05:04 P.M. Pacific Daylight Time,
attorneypaul2000@yahoo.com writes:
>PC owes federal income taxes from year 2007.2007 tax return was filed on 11/1/2010. The offer in compromise was approved on August 2011. PC made onlyonepayment toward the offer in compromise since August 2011. Issue: Is the OIC consider in effect to prevent the chapter 7?
>
>
>From my analysis they satisfied the 3 years, 2 years and 240 days rules. If these 3 time rules are satisfied, do I have to worry about tolling of the OIC still being in effect? Is the OIC considered in effect7?
>
>
>Thanks
>
>
>Paul Horn
>Attorney at Law
>Certified Public Accountant
>850 E. Las Tunas Drive
>San Gabriel, CA 91776
>800-380-7076
>
>
>
The post was migrated from Yahoo.
Hello Paul:
Yes, it is too close to rely on a guesstimate. The SOL date has to be
calculated exactly. Tell
me how long the SOL was tolled exactly.
Sincerely yours,
Robert Suhajda, MS, CPA,
Robert Suhajda,
Business and Tax Consultant
In a message dated 6/1/2013 5:05:04 P.M. Pacific Daylight Time,
attorneypaul2000@yahoo.com writes:
PC owes federal income taxes from year 2007. 2007 tax return was filed on 11/1/2010. The offer in compromise was approved on August 2011. PC made only one payment toward the offer in compromise since August 2011. Issue: Is
the OIC consider in effect to prevent the chapter 7?
The post was migrated from Yahoo.
It tolled plus an additional I believe 240 days.
Sent from my Stella Havkin's IPhone
On Jun 1, 2013, at 5:04 PM, Paul Horn wrote:
> PC owes federal income taxes from year 2007. 2007 tax return was filed on 11/1/2010. The offer in compromise was approved on August 2011. PC made only one payment toward the offer in compromise since August 2011. Issue: Is the OIC consider in effect to prevent the chapter 7?
>
> From my analysis they satisfied the 3 years, 2 years and 240 days rules. If these 3 time rules are satisfied, do I have to worry about tolling of the OIC still being in effect? Is the OIC considered in effect>
> Thanks
>
> Paul Horn
> Attorney at Law
> Certified Public Accountant
> 850 E. Las Tunas Drive
> San Gabriel, CA 91776
> 800-380-7076
>
>
The post was migrated from Yahoo.
PC owes federal income taxes from year 2007.2007 tax return was filed on 11/1/2010. The offer in compromise was approved on August 2011. PC made onlyonepayment toward the offer in compromise since August 2011. Issue: Is the OIC consider in effect to prevent the chapter 7?
The post was migrated from Yahoo.