The IRS has resumed its use of Letter 903, You Haven't Deposited Federal Employment Taxes. Traditionally, Letter 903 was used by revenue officers to alert taxpayers to a potential civil injunction pursuant to IRC § 7402(a) and possible criminal prosecution under IRC § 7215. Nicole Hamlett's article discusses the history of Letter 903, how the IRS is using it today and the best practices for a taxpayer's response.
Erica Son discusses IRC § 6330(c)(1) and the Appeals Division's unconditional obligation to verify that the IRS satisfies the requirements of any applicable law or administrative procedure before seizing a taxpayer's property. She also recommends best practices for (a) causing the Appeals Officers to perform a comprehensive investigation of the IRS compliance with its rules and regulations, and (b) ensuring that Chief Counsel attorneys review the investigation conducted by the Appeals Office.
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