IRS Releases Levies Against Hall of Fame Former Professional Athlete’s Accounts Receivables

THE CHALLENGE

Our client was a highly visible Hall of Fame former professional athlete, who, as a result of bad advice, had a multi-million dollar tax delinquency owed to the IRS. The delinquent tax balance had been pending for a number of years before our firm was engaged, and the IRS revenue officer assigned to the case had been taking the matter very personally. Immediately, before we were hired, the IRS levied all of the accounts receivable of our client’s post-athletic career business and shut off all of the business’s cash flow.

OUR APPROACH

Shortly after being hired, we obtained financial statements, tax returns, and accountant’s work papers and gained a thorough understanding of our client’s financial condition and ability to pay the IRS. Next we interviewed our client and his prior representatives to learn about the facts and circumstances that created the large IRS delinquency, and the nature of the dialogue between prior representatives and the IRS.

We learned that our client’s tax problems were not his fault, but were the result of his reliance on bad advice. We also learned that prior representatives had taken a very adversarial approach to dealing with the IRS and created a distrust among IRS agents handling the case and a resentment of our client’s high-profile status. Our client’s business gave him the ability to make significant payments to the IRS over a reasonable period of time, but the IRS levies were causing his clients to stop doing business with him, and after a few weeks created an existential threat to his business.

We agreed on a strategy that included full transparency with the IRS and communication that would foster trust, cooperation, and achievement of a mutually beneficial solution. We provided the IRS with summaries of our client’s financial position, as well as supporting documents. We explained to the revenue officers handling the case how bad advice had created the problem and proposed a resolution that would include a lump sum down payment with installment payments to follow. We showed revenue officers how levies had crippled the business and threatened its very existence. After multiple meetings, and a great deal of effort, communication improved and the IRS saw things our way.

THE RESULT

The IRS released the levies and allowed our client to pay his delinquent balance in installments. We communicated the resolution and release of levies to our client’s clients. All of them were reassured and agreed to continue to do business with him.