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PRACTICE & PROCEDURES

Press 3: For questions on busi- If the number is 866-897-0177, press ■ A Notice of Federal Tax Lien has
ness accounts not in collection or 2 (Wage and Investment Examination). been filed and all administrative
examination status that involve issues remedies under the law have lapsed
concerning locating payments, mak- Need to release a federal or have been exhausted; or
ing adjustments, general procedural tax lien ■ A levy has been issued.
guidance and time frames, providing Requests for lien discharges, withdraw- The IRS will send the taxpayer a no-
taxpayer transcripts, securing income als, and subordinations are being as- tice CP508C notifying the taxpayer that
verification, employee identification signed within 10 days, according to the he or she has a seriously delinquent tax
number verification, forgotten/lost IRS website as of this writing. Use the debt that has been certified to the State
CAF numbers, and explaining IRS e-fax line for the Advisory Consolidated Department. The IRS will send the
communications. Calls are limited to Receipt (ACR) site (844-201-8382) for taxpayer a notice CP508R at the time
five clients and 30 transcripts per call the request. IRS Publication 4235, Col- it reverses a certification. The taxpayer’s
(increased from 10 transcripts on Nov. lection Advisory Offices Contact Informa- representative will not receive a copy of
15, 2021). tion, lists the Advisory Group phone and the CP508C or CP508R even though
Press 4: If a client’s account is in fax numbers and mailing addresses and the power of attorney is on file.
Automated Collection System status. provides more information on how to Internal Revenue Manual (IRM)
Press 5: For questions about an submit applications for lien certificates Section 5.1.12.27, Passport Revocation,
Automated Underreporter Notice that and related topics. explains ways that a taxpayer may obtain
a client received. There is normally a a reversal of the revocation. A taxpayer
phone number on the top right-hand Reversing passport may submit full payment of the liability
corner of the Notice’s front page. revocation or submit a processable offer in compro-
If the phone number is After a COVID-19-related pause in mise (OIC). Pending installment agree-
800-829-8310, press 1. activity, the IRS in July resumed notify- ments will also reverse the revocation, as
If the phone number is ing the State Department of taxpayers will having the taxpayer’s account placed
800-829-3009, press 2. certified as owing seriously delinquent in currently not collectible status.
If the phone number is tax debt, to enable the department to
877-571-4712, press 3. take actions such as denying the person’s Responding to notices
Press 6: If a client’s account is passport application or revoking a cur- Read all notices carefully. Because
under Correspondence Examination, rent passport. Under these passport notices are changing, make sure to
there is normally a phone number at the rules, seriously delinquent tax debt double-check due dates and if the
top right-hand corner of the notice’s means owing the government more than notice is offering Collection Appeals
front page. $54,000 (adjusted yearly for inflation) Program (CAP) rights (i.e., the right
If the number is 866-897-0161, in back taxes, penalties, and interest, to appeal the IRS’s filing of a levy or a
press 1 (SB/SE Examination). for which: federal tax lien).

EXECUTIVE SUMMARY from a variety of sources in the IRS notice is answered, a practitioner
including the Practitioner Priority should generally follow up with the
• In today’s environment, a tax Service, a local stakeholder IRS after 60 days if a response is
practitioner must be patient and liaison, the Taxpayer Advocate not received.
document all contact with the IRS. Service, and others.
• For cases going to Appeals, prac-
• Although the IRS is opening cor- • Make sure to carefully read every titioners should obtain a copy of
respondence within the normal notice sent to a client. Because the taxpayer’s administrative files,
time frames, processing is taking notices are changing, double- either through the case file access
longer than usual. check due dates and appeal procedures or a FOIA request.
rights that are being offered. Even
• Practitioners can obtain assis- though the IRS has said that no
tance with their clients’ tax issues further action is needed once a

28 January 2022 The Tax Adviser