Compromises and Closing Agreements

For Criminal Tax Matters Involving Compromises and Closing Agreements, Contact an Experienced Attorney

One potential remedy for taxpayers in trouble with the IRS is the Offer in Compromise (OIC) by which tax debts are settled for a compromised amount. The IRS will generally accept offers in compromise only when the agency has reason to believe that a taxpayer cannot pay more than the amount settled upon in the OIC. Before accepting an OIC, the IRS will require evidence that you have no other assets to sell and raise more money, and that you have no ability to increase your income.

Offers in Compromise

In some instances, offers in compromise amount to significantly less than the original tax due amount. This prospect may lead a taxpayer to conceal certain assets in the accounting of all property available — cash or other assets — to reduce the total amount due to be agreed upon in the offer in compromise.

It is a criminal offense to hide, conceal or remove assets in the course of negotiation of an offer in compromise. For instance, if the government has reason to believe you moved your vacation home into a sham trust or transferred it into another person's name immediately before reporting all your assets, the government is likely to file criminal charges. Contact a lawyer with substantial experience handling criminal tax matters.

Attorney Lawrence Brown, a former Department of Justice Tax Division Trial Attorney, limits his law practice almost exclusively to problems with the IRS, both civil and criminal — including criminal charges associated with offers in compromise and closing agreements.

Closing Agreements

The criminal charges regarding concealing or removing assets in connection with an offer in compromise may come about at the point of the closing agreements, when the IRS is attempting to close the collection case. You may be asked if you will ever be able to repay the missing due amount — and making false statements at this stage could result in criminal charges.

For additional in-depth information on Compromises and Closing Agreements, please visit our Criminal Tax Corner - False or Fraudulent Statement Relating to a Closing Agreement in Violation of Section 7206(5)

Call Attorney Brown Toll Free for an Initial Consultation

To contact Brown, PC from anywhere in North America or the world regarding criminal charges connected with compromises and closing agreements, call 888-870-0025. Centrally located in the Dallas-Fort Worth area in Texas, the law firm is a national and international law practice.

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