If I do an installment agreement for a taxpayer can I then go back and make the argument that the original debt was less than the IRS was claiming or must I make that claim first before the installment agreement?
Background - Have a new client who is having IRS Garnishment and NCDOR seizure of bank accounts because in 2006 he didn't file Sch D. As we all know it's almost a lead pipe cinch that he doesn't owe as much as they are claiming but it may take me a while to help him get the basis info together. I am therefore thinking that an immediate IA might buy him some breathing room but I am concerned it would then be too late to claim his basis.
And I agree that he made his bed but since he wants to pay me to help him make it as comfortable as the law and the facts allow I intend to do just that.
Background - Have a new client who is having IRS Garnishment and NCDOR seizure of bank accounts because in 2006 he didn't file Sch D. As we all know it's almost a lead pipe cinch that he doesn't owe as much as they are claiming but it may take me a while to help him get the basis info together. I am therefore thinking that an immediate IA might buy him some breathing room but I am concerned it would then be too late to claim his basis.
And I agree that he made his bed but since he wants to pay me to help him make it as comfortable as the law and the facts allow I intend to do just that.
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