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TAX REMEDIES – The King Law Reporter February 2018 # 3


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Reporter # 3 Feb. 23 2018


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As we know, the IRS has contracted with several private debt collectors to collect federal taxes.


Golly – What could go wrong?


Private debt collectors are subject to the federal Fair Debt Collection Practices Act (“FDCPA”), as well as many state statutes similar to the federal act. When the IRS announced that private debt collectors would collect taxes, it said that they would be subject to that FDCPA. That statute ostensibly protects consumers from a variety of abusive collection methods.


As of June of last year Congress identified several ways in which the tax collectors are violating the FDCPA.


In a June 2017 article, The New York Times posted this article:


Outside Collectors for I.R.S. Are Accused of Illegal Practices


“Pioneer is unique among I.R.S. contractors in pressuring taxpayers to use financial products that could dramatically increase expenses, or cause them to lose their homes or give up their retirement security,” the senators wrote. “No other debt collector makes these demands.”


On Thursday, in advance of receiving the letter, the I.R.S. said it was comfortable with the approach its outside collectors were taking. The agency “is committed to running a balanced program that respects taxpayer rights while collecting the tax debts as intended under the law,” said Cecilia Barreda, an I.R.S. spokeswoman.


The debt collectors are paid on commission, keeping up to 25 percent of what they collect.


Pioneer instructs its employees to “suggest that liquidating assets or borrowing money may be advantageous” and to “give the taxpayer ideas on where/how to borrow,” according to the scripts it submitted to the I.R.S. for approval. If that route does not work, the scripts show, Pioneer’s collection agents encourage taxpayers to ask their family, friends and employers for money.


All four of the collection companies hired by the I.R.S. – CBE Group, ConServe, Performant Recovery and Pioneer – tell debtors that they can set up an installment plan lasting as long as seven years, two years longer than the span that private collectors are legally allowed to offer. The code that authorizes the I.R.S. to hire outside collectors says that they may offer taxpayers installment agreements that cover “a period not to exceed five years.”


The I.R.S. said that payment plans lasting longer than five years were legal as long as they were approved by the agency.


“If the taxpayer agrees, and after the I.R.S. approves, the private firm will monitor payment arrangements between five and seven years,” Ms. Barreda said. “This process is in accordance with the law and ensures that taxpayers assigned to the private firms will have the same payment options as taxpayers dealing with the I.R.S.”


Others disagree with the agency’s interpretation. Nina E. Olson, the national taxpayer advocate at the I.R.S., said that the agency was engaging “in legalistic gymnastics to justify something the law doesn’t allow.”



But collection abuses are not the only problem. The net cost to collect seems really wrong.   


Another New York Times article identified this problem by Nina E. Olson, the taxpayer advocate at the Internal Revenue Service.


“When Treasury Secretary Steven Mnuchin was asked at his confirmation hearing what he thought about using private companies to collect money owed to the government, he replied that it “seems like a very obvious thing to do.”


It may have been obvious, but it certainly was not economical.


Private debt collectors cost the Internal Revenue Service $20 million in the last fiscal year, but brought in only $6.7 million in back taxes, the agency’s taxpayer advocate reported Wednesday. That was less than 1 percent of the amount assigned for collection.


What’s more, private contractors in some cases were paid 25 percent commissions on collections that the I.R.S. made without their help, according to the annual report by Nina E. Olson, who heads the Taxpayer Advocate Service, an independent office
within the I.R.S.



My 2 cents:

As a general rule we have little sympathy for debt collectors who conduct abusive collection activities. However, there are some situations where the FDCPA appears to hobble good intentions.

For example: The FDCPA, at 15 U.S.C. § 1692c(b), provides a restriction on sharing any information about their involvement, with a 3rd party. But § 1692d(6) provides that the collector cannot contact the debtor without disclosing its identity.

What do they do with caller identification that is found on many phones? If the collector decides to leave a message, what does he put in caller id.? I have observed calls come in where the caller id. says “unknown caller.” Does that violate § 1692d(6)? If they leave their identity on the caller id., does that violate § 1692c(b)?


There are simply oodles of cases addressing FDCPA violations for both letters and phone calls in connection with consumer debts. I expect the private tax collectors to do the same. Hence, it won’t hurt for the debtors’ attorneys to become familiar with FDCPA practice in cases involving private IRS tax collection.

(CLICK HERE or Visit BankruptcyBooks.com, click on BOOKS & LETTERS at the top of the page, and select “Abusive Debt Collection.” 



2 cents from California attorney Cathy Moran:

Excise Tax On IRS Proof of Claim Wrongly Inflates Tax Debt


IRS caught double dipping?


In this case, he third amended IRS claim in my client’s case added entries for an excise tax for 2015 and 2016.


Excise tax?


New one on me where the debtor was a general contractor.


I called the IRS agent on the POC for some hints as to what the tax was all about . I needed to know how to analyze whether it was real and correct. It was enough money to threaten the feasibility of the already precarious Chapter 13 plan.


Comes back the answer: it’s the penalty for not having health insurance as required by the Affordable Care Act.


A call to the accountant who prepared the return, and she caught the IRS up in their blunder. The no-insurance penalty is already included in the debtor’s 1040 on line 61. 


The original IRS proof of claim carried the unpaid balance from the client’s tax return straight to the claim. But as I learned, that number already included the tax penalty for no insurance.


So, a separate priority claim for “excise tax” was simply duplicative.


I have no reason to think, yet, that it’s a nefarious scheme to eradicate the national debt via bankruptcy proofs of claim. But there was certainly something unsettling about the reaction of the IRS agent with whom I’ve worked for decades.


When I asked about the “excise tax,” his reaction was a variation on “huh?” Then he shouted out to a co worker and repeated to me that I could find the calculations on form 1095.

Only the accountant tells me that form 1095 is the one the employer uses to report providing health insurance. That form doesn’t appear in the employee’s return.


Be forewarned! 


I have no idea whether this issue is pervasive or a one-off occurrence. But now you can watch for it and snuff it out where the client has already shouldered the penalty for going bare. 




Reporter # 3 Feb. 23 2018



Held, trustee could avoid a lien securing tax penalties, for the benefit of the estate, but not for the benefit of the debtor.


Hutchinson v. United States (Bankr.E.D. Cal. 2018) 


The chapter 71 trustee may avoid liens against estate property for fines, penalties, or forfeitures and preserve those liens for the estate. If the trustee does not do so, the debtor may avoid the lien and preserve it for the debtor’s own benefit. Among the liens that the trustee (but not the debtor) can avoid are liens for tax penalties. If the trustee avoids such a tax lien, for whose benefit is the lien avoided?


The Hutchinsons filed a chapter 7 bankruptcy. The trustee overseeing their case is James E. Salven. Among the assets of the estate listed in their schedules, the Hutchinsons listed their residence, which they valued at $185,000. It is encumbered by a first deed of trust in the amount of $87,000.

The Hutchinsons claimed an exemption for their home in the amount of $100,000.


When the trustee did not exercise his tax-lien-avoidance powers under §§ 724(a) and 726(a)(4), the Hutchinsons filed a complaint to avoid the penalty component of the tax lien under § 522(h) and to preserve that lien for their benefit to the lesser of the § 726(a)(4) claim or the $100,000 homestead for their benefit. See 11 U.S.C. § 522(i)(2).


The Hutchinsons named the IRS and Salven as defendants. Salven answered and cross-complained.

The IRS has moved to dismiss, arguing that only the trustee has standing to assert § 724(a) lien-avoidance rights and that § 522(c)(2)(B) allows it to assert its lien against exempt property. The debtors oppose the motion, asserting (1) their entitlement to assert § 724(a) lien-avoidance rights, provided the trustee does not do so, and (2) their right to preserve for their benefit the lien avoided. 


 But § 522(i)(2) conditions the debtor’s preservation of an avoided lien on the debtor’s avoidance of such lien under § 522(h) together with the other lien-avoidance statutes incorporated into that subsection.  


In this case, § 522(c)(2)(B) precludes the debtors from ever invoking § 522(h) to avoid a tax lien securing penalties. It follows that the debtors cannot rely on § 522(i)(2) to preserve an avoided tax lien for their benefit.

Furthermore, § 551 controls, and, if avoided, the tax lien is preserved for the estate, and derivatively, creditors. Simply stated, if the trustee acts to avoid the penalty component of a tax lien, the lien is preserved for the estate.


The Bankruptcy Code precludes the debtors from avoiding the IRS’s tax lien for penalties. Because the debtors cannot avoid this lien, the debtors cannot preserve it for their own benefit. Section 551 controls when the trustee avoids a lien. If the trustee avoids the IRS’s lien, § 551 authorizes the trustee to preserve the lien for the benefit of the estate’s creditors. For each of these reasons, the United States’ motion to dismiss is granted with prejudice.


ed. note: What is sometimes confusing about liens on tax penalties is the distinction between avoidance for the benefit of the estate, and avoidance for the benefit of the debtor. The general rule appears to be that avoiding a lien securing a tax penalty should be deemed to apply only to the trustee’s power to strip or nullify such a lien. See discussion in Discharging Taxes, ¶ 6.11(c).



HELD: IRS “penalty” for failure to carry personal health insurance is a non-priority penalty, not a “tax.”


In re Chesteen (Bankr. E.D. La. 2018)

A Chapter 13 case:

This matter came before the court on December 6, 2017 on the debtor’s objection to the Internal Revenue Service proof of claim. After reviewing the parties’ briefs, the court holds that the debtor’s objection is sustained. The $695.00 exaction charged to the debtor is more properly characterized as a penalty, not a tax, and as such is not entitled to priority treatment under § 507(a)(8) of the Bankruptcy Code.

The opinion concludes “Congress itself labeled the ACA individual mandate a “penalty” and not a tax. The relevant statute, 26 U.S.C. §5000A, refers to the ACA individual mandate as a “penalty” eighteen times; not once does it refer to the exaction as a “tax.”

Thus, it cannot be said that the ACA individual mandate is an exaction imposed for the purpose of supporting the government. Congress’s primary, or dominant, purpose of imposing the individual mandate of the ACA was not to support or fund the government fiscally, but to discourage Americans from living without health insurance coverage. Therefore it is not an exaction imposed “for the purpose of supporting the Government,” and so it is not a “tax” within the meaning of § 507(a)(8).

An exaction not enacted for the primary purpose of fiscally supporting the government, is a penalty that should not be entitled to priority as “tax” claims.  


Accordingly, because the individual mandate is a penalty, and not a “tax” within the meaning of 507(a)(8), the IRS’s $695.00 claim is not entitled to priority status. The debtor’s objection to the IRS proof of claim is sustained.


CAVEAT: A tax penalty is dischargeable in chapter 7 only if the event causing the penalty happened more than 3 years before the petition is filed. In chapter 13 it is always dischargeable.






Reporter # 3 Feb. 21 2018     



From King’s Discharging Taxes in Consumer Bankruptcy Cases 2018

¶ 2.9(c)(5)(ii)

Emerging issue – Equitable Tolling of the 2-year period


The author is informed that the IRS position is that a prior bankruptcy or CDP appeal stops the clock on the running of the two-year period in the same manner as the 3-year or 240-day periods.


CAVEAT: An emerging issue: Keep an eye out for any case where a prior bankruptcy or CDP hearing overlaps the running of the 2-year period; the IRS now takes the position that those prior events, described in the hanging paragraph attached to § 507(a)(8)(G), toll the running of the 2-year period, based on equitable tolling.


The author is aware of only a handful of cases that have imposed tolling of the 2-year period.


The court in Putnam v. I.R.S.[1] held that a prior bankruptcy suspends the running of the 2-year period, based on the principle of equitable tolling. In other words, it is unfair to the IRS to lose their full two years to collect before the taxpayer files bankruptcy, while not being able to collect during that full period because of the automatic stay of the prior bankruptcy.


In 2005 Congress adopted BAPCPA which explicitly codified the Young principles into its tolling provisions as to the 3-year and 240-day periods. The Bankruptcy Code, however, does not include the 2-year tax return filing date in its tolling provisions prescribed at 11 U.S.C. § 507(a)(8)(G)  


Equitable tolling was the theory behind the Supreme Court’s decision in Young v. United States which held that a prior bankruptcy tolls the running of the 3-year period based on equitable tolling principles.


Putnam addressed several issues, including whether or not the 3-year period prescribed at § 507(a)(8)(A) was a statute of limitations (only a statute of limitations is subject to equitable tolling), and whether the equities favored the IRS such that a prior bankruptcy would suspend the running of the 32-year period.


The court held “yes” to both questions.


“Petitioners point to two provisions of the Code, which, in their view, do contain a tolling provision. Its presence there, and its absence in § 507, they argue, displays an intent to preclude equitable tolling of the lookback period.”


“Whereas the three-year lookback period contains no express tolling provision, the 240-day lookback period is tolled “any time plus 30 days during which an offer in compromise with respect to such tax that was made within 240 days after such assessment was pending.” § 507(a)(8)(A)(ii). Petitioners believe this express tolling provision, appearing in the same subsection as the three-year lookback period, demonstrates a statutory intent not to toll the two-year lookback period.”


“If anything, § 507(a)(8)(A)(ii) demonstrates that the Bankruptcy Code incorporates traditional equitable principles.”  


Another North Carolina case, In re Ollie-Barnes[5] cited both Putnam, Hollowel, Tibaldo, and Teeslink as precedential and persuasive and invoked equitable tolling in that case, with no analysis. The debtor in that case had been in two previous bankruptcy cases, all of which appear to have overlapped into the two-year period.


In most non-tax situations where equitable tolling is applicable it must be shown that the individual was guilty of some kind of bad faith conduct.[6] 


But not only did Young adopt equitable tolling in cases of prior bankruptcy, it also stripped from it the necessity to demonstrate some kind of bad faith or wrongdoing on the part of the debtor:


“Tolling is in our view appropriate regardless of petitioners’ intentions when filing back-to-back Chapter 13 and Chapter 7 petitions – whether the Chapter 13 petition was filed in good faith or solely to run down the lookback period. In either case, the IRS was disabled from protecting its claim during the pendency of the Chapter 13 petition, and this period of disability tolled the three-year lookback period when the Youngs filed their Chapter 7 petition.”[7] 


Some courts hold onto the principle that to impose equitable tolling good or bad faith conduct applies and the court must consider both the debtor’s and the taxing entity’s conduct.[8] 


What is not clear yet is whether courts suspending the clock on the 2-year period due to equitable tolling will also add the 90 days prescribed at § 507(a)(8)(G).



If you have a potential tolling issue in connection with the 2-year period and wish to play it safe by assuming a prior bankruptcy tolls the period, to be really safe add 90 days on to the time the bankruptcy stay stopped the clock.


Another Caveat:In theory, the doctrine of equitable tolling could be applied to things other than a prior bankruptcy if they automatically prohibit collection while the action is pending, such as request for an installment plan or request for innocent spouse relief where the period the application is pending overlaps the 2-year period (or any other time rule).


The other case, In re Hollowell[10], cited the court’s equitable powers under § 105(a) (power of the court) to the effect that the debtor had deliberately manipulated his bankruptcy cases to try to satisfy the two year rule:


“This court is of the opinion that the facts of this proceeding warrant invocation of the § 105(a) equitable power. As such, the court concludes that the two-year period of § 523(a)(1)(B)(ii) was tolled or suspended for the time that the debtors’ previous bankruptcy case was pending, plus an additional six months after the dismissal …”


The court in In re Tibaldo[11]:


“It is unlikely that Congress intended the exception from discharge period to run during a bankruptcy when the IRS is automatically stayed from collecting taxes. This court, therefore, finds that the two year period for dischargeability is suspended as long as the automatic stay precludes the IRS from proceeding against a debtor in bankruptcy.”


In addition to § 105(a) (Hollowell), some courts cite § 108(c) (Extension of time) (Tibaldo).


Arguments can be made against the 2-year tolling rule. One, for example, is that since Congress explicitly codified Young’s equitable tolling to suspend the 3-year and 240-day periods, they obviously had tolling on their minds, but did not apply tolling to the 2-year period. A tenet of statutory construction is that where Congress includes particular language in one section of a statute but omits it in another, it is generally presumed that Congress Acts intentionally and purposely in the disparate inclusion or exclusion.”[12] In BAPCPA Congress included explicit tolling language into § 507 (the 3-year and the 240 day periods prescribed at §507(a)(8)(A)), but not in § 523(a)(1)(B) (the 2-year rule).[13] 


Where stay expired or did not arise in prior bankruptcy


One of the quirks of BAPCPA may, in some cases, result in a benefit for a debtor by not tolling the 3-year or 240-day period on account of one or more prior bankruptcies;


The precise wording of the tolling section of the Code provides that a § 507(a)(8)(A) time period is tolled for the time ” … during which a governmental unit is prohibited … from collecting a tax as a result of … a prior case under this title … or during which collection was precluded by … 1 or more confirmed plans … plus 90 days.” (hanging paragraph following subsection “G”). Thus, it is not the existence of an open bankruptcy case that tolls the period, but only the existence of the automatic stay, if any.


In the case of a one-time serial filer who had a prior bankruptcy case pending within the year leading up to filing bankruptcy again, the stay expires on the 30th day following the filing of the petition, unless the debtor both files and has heard a motion to extend within the 30 days, based on justifiable circumstances.

Thus, if the prior bankruptcy was pending during one of the § 507 time periods, unless extended by the court, the stay in that case will toll the period for the duration of the stay (only 30 days) plus 90 days. The remainder of the time that the bankruptcy case is open will not extend the tolling of the discharge time-period.


Likewise, in the case of a multiple serial filer who had two or more prior bankruptcy cases pending in the year before filing the new bankruptcy, the stay never arises at all, unless imposed by the court pursuant to a timely motion under Code § 362(c)(3)(B), or 362(c)(4)(B). Where the automatic stay was not imposed in such a case, it appears the case would have no tolling effect of either § 507 time period.


TIP: If there has been a prior bankruptcy case which overlapped the running of either the 3-year or 240-day period, the respective time period may not necessarily have been tolled; the prior case or cases may have had the stay in effect for only 30 days, or not at all. See discussion at “6” above.


Notwithstanding the above, however, BAPCPA case law has raised a fine point about the expiration of the stay; the majority of published opinions hold that the termination of the stay after 30 days pursuant to 11 U.S.C. § 362(c)(3) applies only to the debtor and property of the debtor, but not property of the estate. Property of the estate continues to be protected by the stay,[14] at least as long as it remains property of the estate.


It would appear, therefore, that collection by the taxing entity may have been prohibited as against property of the estate, but not as to the debtor personally or his or her property (such as, for example, an ERISA qualified retirement plan, which has been held to be not property of the estate). So, the question is, against what, exactly, was the taxing entity prohibited from collection, and how might this affect tolling? An argument can be made that, since the taxing entity was prohibited from collection as against the property of the estate only, the tolling only affects the estate, but since the stay expired as to the debtor and property of the debtor, the § 507 time periods were not tolled, or were tolled only for 30 days, plus 90 days.


Furthermore, keep in mind that the automatic stay does not protect a non-filing spouse or other 3rd party under the co-debtor stay provision of Code § 1301 (the co-debtor stay only applies to consumer debts, and the majority of opinions hold that tax liabilities are not consumer debts[15]). Accordingly, in such a co-debtor situation the § 507 time periods appear not to have been tolled at all as against the non-filing, co-liable individual.


[1]Putnam v. I.R.S. _ B.R. _ (Bankr.E.D.N.C. 2014). Putnam cited two pre-BAPCPA opinions that apparently ruled the same way; Hollowel v. IRS 222 B.R. 790 (Bankr.N.D.Miss 1998), Tibaldo v. U.S. 187 B.R. 673 (Bankr.C.D. Cal 1995).






From FastCase



From TopForm 





From the office of the Taxpayer Advocate:


The Office of the Taxpayer Advocate is currently conducting a number of new and continuing research initiatives


Taxpayer Advocate Service – Fiscal Year 2018 Objectives Report to Congress – Volume One


The National Taxpayer Advocate is a strong proponent for the role of theoretical, cognitive, and applied research in effective tax administration. The Office of the Taxpayer Advocate is currently conducting a number of new and continuing research initiatives


A primary focus of TAS research initiatives is to better understand taxpayer compliance behavior and to evaluate IRS programs by balancing the goals of taxpayer compliance with minimizing taxpayer burden


Following is a discussion of several research initiatives TAS will begin or continue to conduct for the remainder of fiscal year (FY) 2017 and FY 2018




TAS Research is conducting a study to evaluate the effectiveness of the IRS Offer in Compromise (OIC) program.


The IRS conducted an OIC study over a decade ago that examined the frequency of taxpayers submitting multiple offers within a short period of time, the future compliance of taxpayers with accepted offers, and a comparison of the dollars collected when an OIC was rejected or returned versus dollars collected through other collection methods


Similar to the previous study, TAS will:


  • Quantify the number of taxpayers who have submitted multiple OICs in a short amount of time;
  • Examine the subsequent filing and payment compliance for the next five years after the IRS accepts a taxpayer’s OIC;
  • Determine if subsequent compliance continues beyond the five years required as part of the accepted OIC agreement;
  • Compare the amount the IRS could have collected on a rejected or returned;
  • OIC to the amount actually collected subsequently; and
  • Determine if the IRS estimation of the reasonable collection potential on liabilities of rejected offers is actually realized


The TAS OIC study will particularly focus on dollars collected from taxpayers with rejected or returned OICs versus what the IRS could have collected if it had accepted the offers from the taxpayers. TAS will evaluate whether the IRS left money on the table when it rejected or returned a taxpayer’s offer in favor of pursuing other collection methods such as refund offsets, voluntary payments, or levies. We anticipate beginning this study in FY 2017 and completing it in FY 2018.




A previous TAS Research study showed that trust in government has a significant impact on the compliance of taxpayers whose Schedule C returns were audited by the IRS.


The current TAS study hopes to validate that trust in the IRS, as well as taxpayers’ perceptions of legitimacy or coerciveness of the IRS powers to enforce compliance, affect taxpayers’ accurate voluntary reporting of income and expenses.


During FY 2017, TAS worked with a contractor to develop a survey document, which TAS Research tested at the IRS Ogden Developmental Center by simulating an actual telephone survey.


Based on watching the test respondents’ reactions to questions, an analysis of their responses, and a debriefing session, we adjusted the survey to ensure that respondents interpreted the questions as intended.


The contractor has reviewed the revised survey instrument and made final adjustments to the questions TAS has received approval from the Office of Management and Budget to begin the data collection.


TAS Research is currently determining the exact sampling frame.


The initial sample groups will consist of taxpayers filing Schedule C who were audited and who have continued to file a Schedule C after the audit.


These groups will be divided by whether the audit was conducted by a correspondence audit, an office audit, or field audit, as well as by whether the audit outcome showed an increase in tax, a decrease in tax, or no change in tax.


We will pair these various groups with a control group of similar taxpayers who

were not audited We will compare the survey responses of both groups, in addition to their subsequent compliance as measured by their Discriminate Income Function score.


We plan to administer the survey at the end of FY 2017 and the beginning of FY 2018. We will analyze the results and publish a study of our findings during FY 2018.






By Michael Cohn

Accounting Today 

Published February 13 2018


Basically this is a new twist on an old scam, the IRS noted. After the cyb ercriminals steal client data from tax professionals and file fraudulent tax returns, they use the taxpayers’ real bank accounts for the deposit. Thieves then employ various tactics to reclaim the refund from taxpayers.


The scam is continuing to evolve in new versions. In one version, the criminals impersonate debt collection agency officials acting on behalf of the IRS. They contact taxpayers to tell them a tax refund was deposited in error and ask taxpayers to send the money to their collection agency.
























 NACBA’s 26th Annual Convention

Starts:  Apr 19, 2018 8:00 AM (MT)
Ends:  Apr 22, 2018 2:00 PM (MT)


NACBA is excited to announce that it will host its 26th Annual Convention in Denver, Colorado in 2018 at the Sheraton Denver Downtown Hotel. Denver’s picturesque scenery is the perfect backdrop for NACBA’s robust convention packed with extraordinary education sessions, unique networking opportunities and a bustling exhibit floor.


“We’re looking forward to providing our attendees with an experience that surpasses all of their expectations. Our goal is for attendees to walk away from the 2018 convention knowing that they made an invaluable personal investment,” stated NACBA President Ed Boltz. “NACBA’s dynamic speakers coupled with the wealth of knowledge shared in sessions and the opportunity to connect with peers while being in the heart of Denver promises to be forum that delivers.


NACBA’s Executive Director, Dan LaBert added, “NACBA is highly anticipating the 26th Annual Convention in Denver. It is the perfect place for our attendees to unwind after a full day of sessions and enjoy time with their colleagues in a sophisticated, culturally thriving city while taking in the spectacular beauty that Denver offers.”

The Sheraton Denver Downtown Hotel will provide attendees with the ideal atmosphere, location and amenities to make their trip to the Mile High City a memorable one.


Click for more information 






King’s Discharging Taxes in Consumer Bankruptcy Cases, is available for purchase. For this and other delinquent tax publications, visit – KingLawMedia.com or MorganKing.com

Books Available


Discharging Taxes

Abusive Debt Collection

IRS Collection Due Process

Consumer Chapter 11

Discharging Student Loans

IRS Offers-In-Compromise

Fundamentals of Bankruptcy Law & Practice

The Means Test

Avoiding & Stripping Liens

Fees & Ethics

3-Vol. Tax Practice Library

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