April 13, 2020

Mary Lee Miller EA, LLC

 

During the COVID-19 pandemic, the last thing you need is the IRS

doing bad things, like auditing you or levying your bank account or

wages.

 

But don’t worry—the IRS is pausing most of its collection and audit

enforcement actions.

 

Installment Agreements

 

If you have an installment agreement with the IRS, then the IRS is

suspending your payments due between April 1 and July 15, 2020.

 

The IRS will not default any installment agreements during this period.

 

Remember—interest will continue to accrue on any unpaid

balances, so if you have the financial resources, you may

want to continue to pay.

 

Offers in Compromise

 

If you have a pending offer in compromise, then the IRS will allow

you until July 15, 2020, to provide requested additional information

to support your offer. The IRS will not close any pending offer in

compromise requests before July 15, 2020, without your consent.

 

If the IRS has accepted your offer in compromise, then you can

suspend all payments toward it until July 15, 2020.

 

The IRS won’t default your accepted offer in compromise for a

failure to file your 2018 tax return. But you should file your

delinquent 2018 return (and your 2019 return) on or before

July 15, 2020, to avoid default.

 

Collection Actions

 

IRS field revenue officers won’t initiate liens and levies

(including any seizures of personal residences) through

July 15, 2020; however, they will continue to pursue high-income

non-filers and perform other similar activities as needed.

 

In addition, consider the following actions:

 

• The IRS won’t initiate new automatic, computer-generated

liens and levies through July 15, 2020.

 

• The IRS will suspend new certifications to the Department of

State for taxpayers who have “seriously delinquent” tax debt

through July 15, 2020. Certification prevents you from receiving

or renewing a passport. If your tax debts are subject to certification;

you should submit a request for an installment agreement, an offer

in compromise, or another collection alternative, prior to

July 15, 2020.

 

• The IRS won’t send new delinquent accounts to private collection

agencies through July 15, 2020.

 

Audits

 

The IRS generally will not start new field, office, or correspondence

examinations through July 15, 2020. But it may start new

examinations where deemed necessary to protect the

government’s interest in preserving the applicable statute of

limitations.

 

The IRS suspended all in-person meetings regarding current

field, office, and correspondence audits. Existing audits will

continue remotely, where possible. You should continue to

respond to any requests for information

you’ve received if you are able to do so.

 

What if you are ready, willing, and able to get your audit

started? The IRS may agree to begin the audit before

July 15, 2020, if it has personnel available.

 

Independent Office of Appeals

 

If you have a case in the Independent Office of Appeals,

then Appeals employees will continue to work your

case. You should promptly respond to any new or

existing requests for information.

 

Takeaways

 

If you have IRS problems, the COVID-19 pandemic is creating

a mercy period for you that ends July 15, 2020. During the

mercy period, the IRS is suspending

 

• installment agreement payments,

• new levies and liens,

• new audits,

• new passport actions, and

• new referrals to private debt collectors.

 

Use this break in IRS enforcement through July 15, 2020,

as a great opportunity to get back on track and solve

any existing IRS tax problems you have, such as

 

• completing and sending in those unfiled tax returns;

• getting an installment agreement in place for your unpaid debts; 

• requesting an offer in compromise for tax debt you will not be able to pay.