The Problem: Underwriters threatened to cancel a $5 million loan 18 days before the pre-IPO company was scheduled to close the deal unless all federal tax liens filed against one of the corporate officer’s numerous properties were removed.

The Sullivan Solution: In less than 72 hours Sullivan Consulting assembled the requisite documents, records and title reports; prepared multiple lien withdrawal petitions; prepared a penalty abatement appeal; and met with the IRS Revenue Officer, Special Procedures Branch Lien Coordinator, and Chief of Special Procedures.  Eight days after the client retained Sullivan Consulting, the IRS withdrew the federal tax liens and eliminated $34,000 in penalties, which allowed the company to close on the loan.

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The Problem: Our client, a licensed securities dealer, attended an “IRS Problem Solving Day,” after which his problems soon began.  Rather than working with the taxpayer toward a reasonable solution, the agency accelerated assignment of his case to the IRS Revenue Officer with whom he spoke regarding compliance.  Our client contacted Sullivan Consulting after the ‘helpful’ Revenue Officer filed a tax lien, and then levied our client’s bank accounts and sales commission proceeds.

The Sullivan Solution: Through a financial statement analysis, we demonstrated that the IRS had not allowed the taxpayer sufficient funds to meet quarterly estimated tax payments in calculating the monthly installment agreement; therefore, default of the agreement was imminent.  On appeal, citing IRS policy and procedure violations, the IRS agreed to release the levies.

Securities brokers are required to file annual statements that certify no tax liens have been filed against them.  Because the existence of the tax lien jeopardized the ability of our client to earn a living, a petition was filed for withdrawal of the Notice of Federal Tax Lien.

The Revenue Officer amended the installment agreement and approved the withdrawal of the tax liens.

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The Problem: A mortgage company, whose previous attempts to negotiate with the IRS and reduce a taxpayer’s sizable income tax debt had failed, retained Sullivan Consulting to facilitate refinancing the customer’s residential and commercial real estate.

The Sullivan Solution: The complexity of the loan required that a petition be filed for discharge of the residential property tax lien in conjunction with a petition for tax lien subordination on the commercial property.  This unorthodox proposal was approved after a comprehensive case review conference with the IRS - Special Procedures Branch Advisor, Group Manager, and Branch Chief.  Our client was able to reduce his tax debt by 75%, so he entered into an affordable monthly installment agreement for the balance.

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