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TAX REMEDIES – The King Law Reporter January 2018 # 2

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The King Law Reporter January 2018 # 2


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Providing prompt notice of new cases, emerging issues, and other timely and important information for professionals who deal with delinquent taxes.




January 2018



In the last release of King Law Reporter I discussed how so-called tax relief television advertisers are less than candid about the current state of IRS  tax collection. I said their commercials usually misrepresent the present state of tax collection, with remarks like “The IRS is coming down harder than before.”


I said that, in fact, IRS acceptances of offers-in-compromise has increased in the last several years, and collection activities is not worse, but in fact is less than in previous years, due in party to reductions in IRS staffing.

My views on this have been justified by a recent article reported in Justia, first appearing in Bloomberg News. Quoting directly from that article:

IRS Criminal prosecution declines:

Declining manpower continues to sap the Internal Revenue Service’s ability to pursue criminal cases, as the number of new investigations dropped by 11 percent over the past year and recommendations for prosecution fell by 18 percent.

The IRS Criminal Investigation Division, which helps send people to prison for crimes such as tax evasion, money laundering and identity theft, opened 3,019 cases in fiscal 2017, compared with 3,395 in 2016. It recommended 2,251 prosecutions, a decrease from the 2,761 it sought in the previous year, the division said Thursday in its annual report.


Click for more criminal prosecution article


And, the TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION has issued a report dated September 29, 2017, about the drop in certain kinds of collection activities affected by staff reduction. Explaining the Automated SFR Program, the report states:


The IRS is authorized under Internal Revenue Code Section 6020(b) to use third-party information to determine and assess a tax liability for taxpayers who have a filing requirement but fail to file a tax return. These cases are primarily worked in the Automated Substitute for Return (ASFR) Program.


ASFR inventory receipts and 30-day letter issuances decreased by 89 and 98 percent, respectively, between Fiscal Years 2009 and 2016. This audit was initiated to evaluate the effect of the ASFR Program on enforcement yield and nonfiler compliance and to determine whether it effectively processed its workload.


The Internal Revenue Manual describes the ASFR Program as a key compliance program, but due to significant resource reductions, it has been cut back substantially. Normal attrition and the inability to hire, reduced nonfiler case creation, reallocation of staff to other collection work, and changes to ASFR inventory selection/work priorities have all contributed to the reduction of ASFR inventory receipts and 30-day letter issuances.


Click for more on this 42-page report 


What does this mean to the practice?


As is often the case, the answer is 2-edged kind of thing; on the one hand, reducing the pressure on taxpayers may provide more time, and hence more opportunities, to provide urgent valuable service to panicked clients – i.e., more time to figure out ways to stop collection; on the other hand, less IRS collection harassment will cause a lot of burdened taxpayers less incentive to reach out for professional help – e.g., retain an attorney, E.A., or other tax professional. Hence, less business for us?


And more on this topic:


IRS Criminal Division report


IRS Criminal Investigation Releases Fiscal Year 2017 Annual Report



The Internal Revenue Service today announced the release of the

Criminal Investigation Division’s (CI) annual report, reflecting significant accomplishments and criminal enforcement actions taken in fiscal year 2017.  


Focusing on employment tax, refund fraud, international tax enforcement, tax-related identity theft, public corruption, cybercrime, terrorist financing and money laundering, CI initiated 3,019 cases in FY 2017.  The number of cases initiated is directly tied to the number of special agents that CI has.


“We have the same number of special agents-around 2,200-as we did 50 years ago,” said Don Fort, Chief, CI.  “Financial crime has not diminished during that time- in fact, it has proliferated in the age of the Internet, international financial crimes and virtual currency. Despite these challenges, we continue to do amazing work, investigating some of the most complicated cases in the agency’s history.  Criminals would be foolish to mistake declining resources for a lack of commitment in this area.”


The annual report is released each year for the purpose of highlighting the agency’s successes while providing a historical snapshot of the make-up and priorities of the organization. The very first Chief of IRS CI, Elmer Lincoln Irey, served from 1919 to 1946 and envisioned releasing such a document each year to showcase the agency’s investigative work.


CI is the only federal law enforcement agency with jurisdiction over federal tax crimes. This year, CI again boasted a conviction rate rivaling all federal law enforcement at 91.5% while spending more than 72% of their investigative time working tax cases. That conviction rate speaks to the thoroughness of the investigations and CI is routinely called upon by prosecutors across the country to lead financial investigations on a wide variety of financial crimes including international tax evasion, identity theft, terrorist financing and transnational organized crime.


CI investigates potential criminal violations of the Internal Revenue Code and related financial crimes in a manner to foster confidence in the tax system and compliance with the law. The interactive report summarizes a wide variety of CI activity throughout the fiscal year and includes case examples from each field office on a wide range of financial crimes.

“Since taking over as the Chief of CI this summer, I could not be prouder to lead the men and women of this organization,” said Fort. As financial crimes-and the way we investigate them-continue to evolve, CI continues to set the standard for financial investigations worldwide.”






American taxpayers are protected from arbitrary or abusive tax collection, as set forth in the IRS Taxpayer Bill of Rights.


To be precise, the TBOR is fairly drafted and provides, at 2 sections:


“5. The Right to Appeal an IRS Decision in an Independent Forum.

Taxpayers are entitled to a fair and impartial administrative appeal of most IRS decisions, including many penalties, and have the right to receive a written response regarding the Office of Appeals’ decision. Taxpayers generally have the right to take their cases to court.”    


Click for Bill of Rights. 26 U.S.C. § 6320, 6330. Internal Revenue Manual § 8.22.4 Collection Due Process Appeals Program. Addressed in King’s Lawyer’s Guide to Collection Due process.  


In my experience, this is generally true.


As an attorney focused on delinquent tax remedies, I have become familiar with the benefits of what is called Collection Due Process Appeal (“CDP”). Appeals using this procedure become available when the taxpayer receives a “final Notice of Intent to Levy” or of “Notice of Lien,” if they file an appeal within 30 days of the notice.  


At the appeal hearing, the statute allows a taxpayer to raise any legal argument, with supporting documentation, such as liability, hardship, defenses such as innocent spouse, and a suggestion of a less intrusive collection or payment arrangement.


In my experience with the CDP appeal hearings, I have generally been satisfied with how the appeals office has addressed the concerns and suggestions I raise on behalf of my clients.




If, upon receipt of the Final Notice of Intent to Levy, the taxpayer fails to appeal  within the 30 days, all is not necessarily lost; the tax code provides what I call “plan B,” an ordinary collection appeal called an “equivalency hearing.” Usually referred to as Collection Appeal Procedure (“CAP”). IRM § 8.24 Collection Appeals Program and Jeopardy Levy Appeals.  


However, my experience with this alternative appeal process is less than satisfactory. In those cases where I’ve filed a collection appeal, the appeal officer generally simply determines if the IRS has followed all required steps, forms, and other technical issues, but takes the position that those are all they need to examine. I’ve experienced the simply reply from the appeal officer that he/she is satisfied that the IRS has taken all required steps, and there isn’t any other thing to talk about.


The other problem is that the CAP must be completed in 5 days! See King’s Lawyer’s Guide to Collection Due process, ¶ 8, Alternatives CDP.


My view is that, except in rare cases, the CAP process is a waste of time. 


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Reporter January 2018 #2


re: F. Lee Bailey, Debtor. (Bankr.D. Maine Oct 3 2017)

Click for full opinion 




  1. Lee Bailey contests IRS actions  


The issue in this case is the famous F. Lee Bailey’s dispute over whether the IRS has the right to collect against his pension and social security benefits.  




“This bankruptcy case is another chapter in the decade long struggle between the Internal Revenue Service (“IRS”) and Mr. Bailey over taxes. Much of that story is set forth elsewhere and is not relevant to the decision here.  


“Now, the United States of America, on behalf the IRS, seeks to enforce its federal tax liens on debtor F. Lee Bailey’s pension accounts and right to Social Security benefits.  


“Mr. Bailey objected to that relief and a hearing was held on September 13, 2017. Following the hearing, the Court took the matter under advisement to determine whether the issue could be determined as a matter of law, as IRS asserts, or whether an evidentiary hearing is necessary, as Mr. Bailey maintains. After consideration of the arguments of counsel, the Court concludes that for the reasons set forth below, IRS’s motion can be addressed without the need of testimony and it will be granted.


“Mr. Bailey, now 84 years old, filed a second bankruptcy case seeking relief under Chapter 13 of the Code from the in rem claims of the IRS and others.  


As in his Chapter 7 case, Mr. Bailey scheduled his three pensions and his Social Security benefits as assets. In August of 2017, the IRS filed this motion through which it seeks modification of the automatic stay to enforce its federal tax liens on Mr. Bailey’s pension accounts and Social Security benefits so it can, among other things, apply the monthly pension payments of $1,483 and the monthly Social Security benefit payments of $1,786 to Mr. Bailey’s past tax obligations.


“[I]t is the position of the Internal Revenue Service that where a taxpayer has an unqualified fixed right, under a trust or a contract, or through a chose in action, to receive periodic payments or distributions of property, a Federal lien for unpaid tax attaches to the taxpayer’s entire right, and a notice of levy based on such lien is effective to reach, in addition to payments or distributions then due, any subsequent payments or distributions that will become due thereunder, at the time such payments or distributions become due.”). And, the liens imposed by 26 U.S.C. § 6321 remain in effect until the taxes are paid or become unenforceable due to the passage of time. 26 U.S.C. § 6322.   


“All that he has proposed to date is that the collateral will be valued and he will borrow enough money to pay it off. That proposal may indeed work at some time in the future but the current state of affairs Mr. Bailey receives the monthly payments from his pension and social security benefits and he uses them for his expenses and to fund his plan erodes the IRS’s collateral.


“What Mr. Bailey seeks is a full adjudication of his challenge to the amount of the IRS

secured claim; in other words, his opposition to the motion for relief from stay is essentially a claims adjudication under § 506. While he is entitled to mount such a challenge, the context of this motion for relief from stay is neither the time nor place. Relief from stay motions, such as IRS’s here, are expedited proceedings designed in part to ensure that secured creditors do not lose the value of their security interests because of the operation of the stay and Mr. Bailey’s proposal does not provide the IRS with the protection that § 362(d)(1) affords.”


ed. Note:


During my adult life F. Lee Bailey was a famous criminal defense lawyer involved in many famous cases. He served as the lawyer in the re-trial of osteopathic physicianSam Sheppard. He was also the supervisory attorney over attorney Mark J. Kadish in the court martial of Captain Ernest Medina for the My Lai Massacre, among other high-profile trials, and was one of the lawyers for the defense in the O. J. Simpson murder case.   


From Wikipedia:  


“He was eventually disbarred. Bailey’s high public profile has come both as a result of the cases he has taken and his own actions. The Florida disbarment was the result of his handling of shares in a pharmaceutical company named Biochem Pharma during his representation of marijuana dealer Claude DuBoc. Bailey had transferred a large portion of DuBoc’s assets into his own accounts. The stock was worth about $5.9 million.” 




Tax Court:  


Held: taxes were not discharged in the bankruptcy


Benjamin Jeffery Ashmore v. Comm’r 11/27/2017,T.C. Memo. 2017-233


Click for full opinion 


This litigation was filed with the United States Tax Court. Issues that were addressed were, did the taxpayer’s bankruptcy prevent IRS tax collection, whether the taxes were addressed or discharged in the Bankruptcy Court and whether the taxpayer complied with requests for documents at the Collection Due Process hearing …


The taxpayer received a final discharge in his Chapter 7 bankruptcy on Nov. 18, 2013.   The debtor claimed his tax liabilities were discharged in the bankruptcy.  The Tax Court issued an order reopening the bankruptcy. The IRS argued that the Tax Court lacked jurisdiction to adjudicate and moved for dismissal.  


The court held that it had jurisdiction to adjudicate the tax liability because the IRS had not filed a proof of claim in the bankruptcy and there was no evidence of an adjudication under 11 U.S.C. § 505(a)(1), and hence the liability was not discharged in bankruptcy court. 


In connection with the CDP hearing, the court held that the debtor had an opportunity to raise his concerns at the hearing, but the IRS was justified in rejecting his appeal because he failed to file a 433-A or file several delinquent tax returns.   


The court held that the CDP hearing officer has not abused discretion in rejecting the taxpayer’s appeal, for several reasons:

  1. The taxpayer failed to provide requested documents.
  2. The taxpayer did not propose any alternatives to levy, such as an offer-in-compromise.
  3. The liability had not been discharged in bankruptcy because of failure to satisfy the rules for discharge, such as the 3-year rule at 11 U.S.C. § 507(a)(8)(A)(i) or (ii). 
  4. The reopening of the bankruptcy did not reinstate the stay – and no motion to reinstate the stay had been made.
  5. The taxpayer was not entitled to attorney’s fees and costs because he was not a “prevailing party.” 


ed. Note:  


This issue is addressed in King’s Discharging Taxes in Bankruptcy, ¶ 5.1.



Held: An IRS Collection Due Process appeal need not toll all forms of tax collection to toll the bankruptcy discharge time-period because, notwithstanding that a CDP does not prevent all methods of tax collection, it is still governed by 11 U.S.C. § 507(a)(8)(G)


Tenholder v. United States (In re Tenholder) (Bankr. S.D. Ill., 2017)


” … the issue is whether the Internal Revenue Service must be completely barred from collecting the tax or if a partial bar will suffice to toll the three year period.” 


The IRS averred that a CDP tolled the 3-year period prescribed at 11 U.S.C. § 507(a)(8)(A). Hence, it could continue collection. The debtor argued that the “flush language” of 11 U.S.C. § 507(a)(8)(G) provides that the time period is not tolled unless the CDP prevented all forms of tax collection; a CDP stops levies, but not other forms of collection:


      “… the argument made by the Debtors, specifically, that the “flush language” of § 507(a)(8) requires all collection efforts to be prevented, not just the prevention of collection of the tax by levy, to toll a bankruptcy time-period. Since a CDP does not stop all forms of collection it does not toll the 3-year period.


“This argument was addressed by the Court in In re Lastra, where the Court rejected the [debtor’s] argument and held that the Internal Revenue Service does

not have to be completely prohibited from collecting a tax in order for the three year period to be tolled. Console v. C.I.R., 291 Fed. Appx. 234 (11th Cir. 2008).  


“This Court … holds that the debt to the Internal Revenue Service for the Debtors’ 2011 income tax is non-dischargable because the Internal Revenue Service’s inability to collect the tax by levy during the pendency of the collection due process hearing was sufficient to toll the three year period of § 507(a)(8).  


ed. Note: This issue, partial prohibition of collection in regard to the effect of a CDP on tolling is addressed in my book, King’s Discharging Taxes in Bankruptcy, ¶ 2.9(c)(7). 




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Reporter January 2018 #2



From, King’s Discharging Taxes in Consumer Bankruptcy Cases, available at The Morgan King Company.


¶ 2.8(n) Debt incurred to pay nondischargeable taxes


Under prior law, a debt incurred to pay a non-dischargeable federal tax claim (such as a credit card used to pay such a claim) was non-dischargeable pursuant to Code § 523(a)(14). Section 314 of the Reform Act added subsection 523(a)(14A) extending the non-dischargeable status to debts incurred to pay non-dischargeable taxes from other than the federal government. Thus, debts incurred to pay nondischargeable state and local taxes are now non-dischargeable.


Held, credit card debt incurred to pay nondischargeable taxes shortly before filing bankruptcy was excepted from discharge pursuant to 11 U.S.C. § 523(a) (14). In re Gavin, 248 B.R. 464 (Bkrtcy. M.D.Fla. 2000).  



NOTE: Although a debt incurred to pay a non-dischargeable tax is itself non-dischargeable in chapter 7, such debts are dischargeable in chapter 13; the exceptions to discharge in chapter 13 at 11 U.S.C. § 1328(a) do not reference § 523(a)(14) or (14A).


NOTE: BAPCPA broadened the nondischargeability of debt incurred to pay federal taxes to include debts incurred to pay state taxes, as well.


The Bankruptcy Reform Act

of 1994 added a new category of tax-related claim that is nondischargeable in Chapter 7. The Act amended 11 U.S.C. § 523(a) by adding a new paragraph, to wit, paragraph (14), which states “incurred to pay a tax to the United States that would be nondis­chargeable pursuant to paragraph (1).”  


The purpose of this amendment is to pre­vent the debtor from using his credit card or otherwise using credit or bor­rowed money to pay a nondis­chargeable tax, and then discharging the credit debt in Chapter 7.  


This rule applies only to taxes owed to the federal govern­ment and ap­plies only in Chapter 7, since the code sections gov-erning discharge of debt in Chapter 13 were not similarly amended.


Is the tax actually owed? Where the tax in question is subsequently determined to be not owed, the exception to discharge does not apply. In re Rollings, No. 7-07-11657 SL (Bankr. N.M. 2/12/2009) (Bankr. N.M., 2009) (Chase Manhattan)


Same: To establish a claim under § 523(a)(14), the plaintiff must establish, at a minimum, that there was a “tax owed” by the defendant that the plaintiff paid. Chase Bank USA v. Mueller (In re Mueller) (Bankr.W.D.Wis., 2011) (Chase Bank).


Where trust-fund tax not assessed. DDC & Assocs. v. White (In re White) (Bankr. N.D. Ind., 2011)


Same: Debtor uses credit card to pay corporate trust-fund taxes, but at the time had not been personally assessed. Held, debtor is legally obligated notwithstanding lack of personal assessment, thus debt was incurred to pay nondischargeable debt. In re Cook, Case No. 08-71839 (Bankr. W.D. Va. 8/28/2009) (Bankr. W.D. Va., 2009) (American Express)


Personal loan extended to debtor to pay taxes; not dischargeable. In Re Dinan, 425 B.R. 583 (Bankr.Nev., 2010), 448 B.R. 775 (9th Cir. BAP 2011).


Must prove taxes were nondischargeable. Held, debt to plaintiff American Express not dischargeable based on credit card fraud, not payment of nondischargeable tax.[1] 


[1] In re Welch, Case No. 08-40031 (Bankr. E.D. Tex. 3/3/2009) (Bankr. E.D. Tex., 2009) (American Express) MBNA American Bank. FIA Card Serv., N.A. v. Travis (In re Travis) (Bankr. W.D. Tex., 2011)



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Trustee sues law firm for irregular billing practices


US Trustee v. Ashcraft (In re Gilmore), Bankr. C.D. Cal., 17-ap-01271, Complaint12/12/17


The U.S. Trustee Program has filed a complaint against a California lawyer and her firm for its so-called “no money down” billing practices in Chapter 7 cases.


Peter C. Anderson, the U.S. trustee for the Central District of California, sued Patricia Ashcraft and the Law Offices of Gregory Ashcraft, APC, related to attorney fees collected for a Chapter 7 bankruptcy the firm filed for Mary Anne Gilmore on May 2.


The Dec. 12 complaint from the Justice Department’s trustee unit overseeing bankruptcies seeks disgorgement, or repayment, of attorneys’ fees, sanctions, and an order preventing such billing in future cases.


The outcome of the case should be noteworthy to firms that provide a no-money-down service for filing Chapter 7 cases, including those that use BK Billing LLC as a means to finance the case.


In Chapter 7, a trustee is appointed to liquidate the debtor’s assets for the benefit of creditors. The debtor ultimately receives a discharge, an order wiping out most debt. The filing also creates an automatic stay, preventing any collection activities against the estate or the debtor.

Most attorneys representing debtors in Chapter 7 insist on being paid in full before they file a case because the automatic stay and bankruptcy discharge prevent collection after the filing as a pre-petition claim.


But Ashcraft has found a means to provide services without any money up front.


From the complaint filed  


US Trustee v. Ashcraft 




  1. This Complaint concerns the Defendants’ Chapter 7 consumer business practices which adversely affected Mary Ann Gilmore, the debtor in this bankruptcy case, and other consumer debtors.  


  1. During the past year, the Defendants increased their Chapter 7 consumer client base nearly five-fold by advertising that they would file individual Chapter 7 bankruptcy cases in exchange for “no money down.”  


  1. Under their new business model the Defendants claim to divide, or “bifurcate,” their representation of Chapter 7 consumer debtor clients into two parts: a prepetition component and a post- petition component.  


The Defendants claim to provide the pre-petition services to clients for “free,” and claim that they charge clients only for the remaining post-petition services. As part of the marketing appeal to would-be clients, the Defendants’ model contemplates that the attorney’s fees for post-petition services will be collected in post-petition monthly installments over the course of a year through ACH- debits of customer bank accounts.


The full complaint is 142 pages, of which most are exhibits.


ed.note: I discuss something similar to this in my book, Fees & Ethics in Consumer Bankruptcy Cases, at ¶ 7.4(d) and 7.4(g), and ¶ 4.1)(c): 


The majority rule is that there is no ex­ception from discharge for attorney’s fees found in 11 U.S § 523 (exceptions to dis­charge). Accordingly, under this rule any attempt by the attorney to collect the fee postpetition, for prepetition services, is a violation of the automatic stay. Several lawyers across the country have already been sanctioned under this policy.


The flip-side is that if the attorney collects, pre-petition, sufficient fees to cover both pre- and – post-petition services, the portion that would ordinarily cover the postpetition fees, but has not been used as of the date the petition is filed, is property of the estate, and must be turned over to the trustee. In re Mondie Forge Co., 154 B.R. 232 (Bankr.N.D.Ohio 1993); In re Saturely 131 B.R. 509 (Bankr.D.Maine 1991). In re Zukoski 237 B.R. 195 (Bankr.M.D.Fla. 1998).   


At ¶ 4.1(b)(2) I give advice that the only way to avoid the discharge of fees prepetition, and having the postpetition portion deemed property of the estate, is to charge 100% of the prepetition fees up to the moment of filing the petition, and collect for postpetition services out of the debtor’s post-petition income.  




Medical debt forces seniors into bankruptcy



By Tami Kamin Meyer 

November 16, 2017


Medical debt is the No. 1 source of personal bankruptcy filings in the United States and people 65 and older now make up roughly 8 percent of bankruptcy filers, up from 7 percent in 2008.


Attorney Bobby Wilbert attributes the increase to a few factors. For one, he says, the recession of 2008 “hit that demographic pretty bad.” Moreover, in some states, creditors may garnish up to 25 percent of a debtor’s disposable net income monthly, “so you have to do something,” says Wilbert.


And with wives traditionally outliving their husbands – who often oversee the family’s finances – a lack of financial literacy leads many older women to bankruptcy court.


Elaine M. Dowling, a solo bankruptcy practitioner in Oklahoma City, attributes much of the uptick in bankruptcies among her clients 50 and older to the high cost of health care. She also says Congress’ massive overhaul of the U.S. bankruptcy code in 2005 didn’t serve its stated purpose of decreasing bankruptcy filings.




Broke Motown great Eddie Holland faces $20M tax debt


Robert Snell, The Detroit News 


Dec. 6, 2017   


Detroit – Legendary Motown songwriter Eddie Holland, who co-wrote the soundtrack of the baby boomer generation, including the hit “Stop! In the Name of Love,” is penniless and trying to stop the IRS from seizing his Social Security benefits to satisfy a $20 million tax debt.


A lawyer for the Rock & Roll Hall of Fame member filed a federal lawsuit Wednesday to hold on to the last asset remaining from a career that generated tens of millions of dollars and dozens of hit songs.






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A veteran Manhattan bankruptcy attorney charged with misappropriating some $800,000 of escrow funds over a period of five months has been immediately suspended from practicing law for alleged misconduct that “threatens the public interest,” a state appeals court ruled Tuesday, brushing back the lawyer’s attempts to clarify what occurred. 


Pincus David Carlebach’s license is suspended until further court order, a unanimous panel of the Appellate Division, First Department, decided. The immediate, interim suspension indicates that the First Department’s Attorney Grievance Committee will look to move forward with full disciplinary charges against Carlebach, and that he may ultimately suffer a heavier punishment.


Click for more information 


The book, King’s Discharging Taxes in Consumer Bankruptcy Cases, is available for purchase. For this and other delinquent tax publications, visit – 
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Discharging Taxes
Abusive Debt Collection
IRS Collection Due Process
Consumer Chapter 11
Discharging Student Loans
IRS Offers-In-Compromise
Fundamentals of Bankruptcy Law & Practice
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Fees & Ethics
3-Vol. Tax Practice Library
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