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Offer in Compromise

The Problem:  A retired airline pilot with a history of heart disease received a reduction in pension of over 50% due to the bankruptcy of his former employer.   Because of the drastic reduction in monthly income and recurring health problems, our client was unable to pay back taxes in excess of $20,000.

The Sullivan Solution: Sullivan Consulting filed an Offer in Compromise saving him $18,500.

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The Problem: In 1993 the IRS accepted a taxpayer’s Offer in Compromise for a $12,500 Trust Fund Recovery Penalty assessment.  But the next year he received an IRS notice that claimed he had defaulted and now owed the IRS nearly $45,000.  Our client retained Sullivan Consulting after his prior representative, an unlicensed practitioner, refused to assist him.

The Sullivan Solution: Sullivan Consulting reconstructed the case by obtaining the original Offer in Compromise investigation files, computer transcripts, and prior representative’s work papers.  Upon filing a Collection Appeal Request, Sullivan Consulting conclusively proved that it was the IRS that erred by misapplying our client’s 1993 Offer in Compromise payment, which caused the default. 

However, due to systematic limitations, the IRS could not reinstate the defaulted Offer in Compromise.  Under the Doubt As To Liability criterion, Sullivan Consulting proposed that the IRS agree to accept a new Offer in Compromise for $1.00.  The IRS accepted.

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The Problem: Due to severe Medicare cuts that prevent the government program from adequately covering the costs of providing 24-hour skilled nursing care, a nursing home incurred a $400,000 employment tax debt.

The Sullivan Solution: Citing the Balanced Budget Act of 1997 and an extensive financial statement analysis, Sullivan Consulting filed an Offer in Compromise based on special circumstances. The IRS Appeals Division conceded the difficulties directly caused by the government Medicare program and accepted an the Offer in Compromise in the amount of $260,000, which accounts for the “Raw Tax” portion of the liability.

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