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All Courses "Terminating" a Pending Offer "Withdrawing" a Pending Offer 341 Meeting of Creditors Accepting an Offer alternatives to bankruptcy Appellate Review Attorney Client Privilege Automatic Stay Bank loans Banking Requirements Bankruptcy Code Bankruptcy Practice Bankruptcy Rules Bar Associations Billing Software Browsers Capital Requirements Certification Chapter 11 Chapter 13 Client Confidentiality Client Development Co-Debtors Collateral Agreements Collection Process Collection Statute Expiration Date Compensation Computer Constitution Corporations Discharge Eligibility Equitable Relief Ethics Examination Executory Contracts Exemptions Expenses Form 8857 Google Guaranteed Installment Agreement Income Injunction Innocent Spouse Relief Installment Agreements Insurance Internet Browser Leases Leasing Legal Structures Levy Limited Liability Companies LLCs Malpractice Marketing Means Test Meeting of Creditors Microsoft Modifying Installment Agreement Non-priority Unsecured Creditors Non-Requesting Spouse Offer in Compromise Offer Processability Office Leasing OIC Scholar Partnerships Personal Property Petition Power of Attorney Power of Attorney and Third Party Authorizations Premature and Untimely Claims Priority Unsecured Creditors Profitability Property RCP Reasonable Collection Potential Refund Claims Regulations Schedule A/B Schedule D Schedule G Schedule H Schedule I Schedule J Section 341 Meeting of Creditors Secured Creditors Separation of Liability Relief Social Media Marketing Software Sole Proprietorships Statement of Financial Affairs Statement of Intent Statutes Stay Streamlined Installment Agreements Technology Terminating Installment Agreement Terms and Conditions Third Party Authorizations Timeline Trustee Unexpired Leases Unsecured Creditors Web Browser Websites
$100

BK 101: Chapter 7 Petition

Chapter 7 Petition. Every individual debtor seeking Chapter 7 bankruptcy relief commences a case by filing a “petition.”  11 U.S.C. § 301.  But what constitutes a petition?  Unlike the U.S. district courts that giver great latitude to drafters of a civil complaint, the U.S. bankruptcy courts do not give similar latitude…
$100

BK 102: Schedule A/B – Property

Schedule A/B: Property Every Chapter 7 debtor must file a schedule of assets that identifies both real property and personal property.  11 U.S.C. § 521(a)(1)(B)(i); Bankruptcy Rule 1007(b)(1)(A).  Real property consists of land and anything permanently affixed to the land, homes, buildings, air rights above the land, and underground rights below the land. …
$100

BK 103: Schedule C – Exemptions

Schedule C: Exemptions. Every Chapter 7 debtor is allowed, but not required, to file a schedule of exempt assets.  Like the petition and Schedule A/B, Bankruptcy Rule 9009 requires a debtor to use a specific national form prescribed by the Judicial Conference of the United States when listing the debtor’s exemptions.  Bankruptcy…
$100

BK 104: Schedule D – Secured Creditors

Schedule D: Secured Creditors. Every Chapter 7 debtor must file a schedule of liabilities that includes both secured and unsecured creditors.  11 U.S.C. § 521(a)(1)(B)(i); Bankruptcy Rule 1007(b)(1)(A).  This chapter focuses on the listing of secured creditors and the following chapter discusses listing unsecured creditors. The creditors listed in Schedule D are limited…
National Bankruptcy Academy
$100

BK 105: Schedule E/F – Unsecured Creditors

Schedule E/F: Unsecured Creditors. Every Chapter 7 debtor must file a schedule of liabilities that includes both secured and unsecured creditors.  11 U.S.C. § 521(a)(1)(B)(i); Bankruptcy Rule 1007(b)(1)(A).  This course focuses on the listing of unsecured creditors and the prior chapter discussed listing secured creditors. The creditors listed in Schedule E/F…
$100

BK 106: Schedule G – Executory Contracts and Unexpired Leases

Schedule G: Executory Contracts and Unexpired Leases. Every Chapter 7 debtor must file a schedule of executory contracts and unexpired leases.  Bankruptcy Rule 1007(b)(1)(C).  This chapter focuses on the listing of debtor’s executory contracts and unexpired leases. What makes a contract an “executory” contract?  An executory contract in the bankruptcy context has…
$100

BK 107: Schedule H, Co-Debtors

Schedule H: Co-Debtors. Every Chapter 7 debtor must file a schedule of co-debtors (also spelled codebtor).  Bankruptcy Rule 1007(a)(1).  This chapter focuses on the listing of a debtor’s co-debtor. What constitutes a co-debtor?  A co-debtor is one or more persons or entities that is primarily liable for the same debt for…
$100

BK 108: Schedule I – Income

Schedule I: Income. Every Chapter 7 debtor must file a schedule of current income, commonly called Schedule I.  11 U.S.C. § 521(a)(1)(B)(ii); Bankruptcy Rule 1007(b)(1)(B).  As discussed below, this statement reveals the debtor’s actual monthly income from all sources of income as of the petition date.  Current income includes income from all…
$100

BK 109: Schedule J – Expenses

Schedule J: Expenses. Every Chapter 7 debtor must file a schedule of current expenses, commonly called Schedule J.  11 U.S.C. § 521(a)(1)(B)(ii); Bankruptcy Rule 1007(b)(1)(B).  Current expenses include actual expenses for rent, mortgages, utilities, food, clothing, medical and dental care, transportation, insurance, taxes, vehicle expenses, etc. Like the other schedules, Bankruptcy Rule…
$100

BK 110: Statement of Compensation

Statement of Compensation. Every Chapter 7 attorney must file a disclosure of compensation for services rendered and reimbursement of expenses.  11 U.S.C. § 329(a); Bankruptcy Rule 2016(b).  Like the schedules, Bankruptcy Rule 9009 requires a debtor to use a specific national form prescribed by the Judicial Conference of the United States…
$100

BK 111: Statement of Intention

Statement of Intention. Every Chapter 7 debtor must file a statement of intention with respect to the retention or surrender of property securing a creditor’s interest.  11 U.S.C. § 521(a)(2).  For any encumbered asset debtor intends to retain, the debtor must state whether the debtor intends to reaffirm the debt…
$100

BK 112: Statement of Financial Affairs

Statement of Financial Affairs. Every Chapter 7 debtor is required to file a statement of the debtor’s financial affairs.  11 U.S.C. § 521(a)(1)(B)(iii); Bankruptcy Rule 1007(b)(1)(D).  Like the Statement of Intent, the Bankruptcy Rules requires a debtor to use a specific national form prescribed by the Judicial Conference of the…
$100

BK 113: Statement of Your Current Monthly Income

Statement of Your Current Monthly Income. Every Chapter 7 debtor must file a statement of current monthly income.  11 U.S.C. § 521(a)(1)(B)(v).  A better term for this statement would have been average monthly income.  As discussed below, this statement reveals the average monthly income from all sources of income during…
$100

BK 114: Statement of Means Test Calculation

Statement of Means Test Calculation. Every Chapter 7 debtor must file Official Form 122A-2, Chapter 7 Means Test Calculation when his/her annualized average monthly income (as calculated in Part 1 of Official Form 122A-1, Chapter 7 Statement of Your Current Monthly Income) exceeds the state’s median annual income for households of…
$100

BK 116: Constitution, Statutes, Rules and Caselaw

Constitution, Bankruptcy Code, Bankruptcy Rules, and Case Law. Embedded in the United States Constitution is the genesis of bankruptcy protection in America.  The Founding Fathers recognized the need for bankruptcy protection as an alternative to incarcerating indigent individuals in “debtors’ prison” – a common way to deal with unpaid debt in…
$100

BK 117: Six Types of Bankruptcy Cases

Six Types of Bankruptcy Cases. The Bankruptcy Code provides six basic types of bankruptcy cases.  Each type of bankruptcy case is codified in a distinct “chapter” of the Bankruptcy Code.  11 U.S.C. § 101 et seq.  Each type of bankruptcy case is identified by the Bankruptcy Code “chapter” number that contains the…
$100

BK 118: Timeline for a Chapter 7 Case

Timeline for a Chapter 7 case. Debtors are frequently apprehensive of and often overwhelmed by the bankruptcy process.  So, a detailed explanation of the Chapter 7 timeline goes a long way to soothing a debtor’s anxiety.  Understand the day-by-day operations of a typical Chapter 7 case.
Robert Schaller
$100

BK 119: Alternatives to a Chapter 7 Case

Alternatives to a Chapter 7 Case. Filing bankruptcy is a last resort for most people.  People in debt try to avoid bankruptcy by “tightening their belts” to reduce monthly expenses so the debts can be repaid over a period of time.  Other people try increasing monthly income by working overtime or…
$100

BK 120: Chapter 7 Eligibility

Eligibility for a Chapter 7 Case. To qualify for relief under Chapter 7 of the Bankruptcy Code, the debtor may be an individual, a partnership, or a corporation or other business entity.  11 U.S.C. § 101(41) & 11 U.S.C. § 109(b).  Bankruptcy relief is available under Chapter 7 regardless of the amount of…
$100

BK 122: Role of the Chapter 7 Panel Trustee

The Role of the Chapter 7 Panel Trustee. The U.S. trustee must be distinguished from a Chapter 7 panel trustee.  This chapter focuses on the Chapter 7 panel trustee. The U.S. trustee in each district has assembled a pool of private people to act as Chapter 7 trustees.  These people are typically attorneys. …
$100

BK 123: Section 341 Meeting of Creditors

Section 341 Meeting of Creditors. The U.S. trustee appoints an impartial “Chapter 7 panel trustee” to administer the Chapter 7 case promptly after the bankruptcy petition is filed with the clerk of the court.  11 U.S.C. § 701.  The Chapter 7 panel trustee must administer the case in accordance with the trustee’s statutory…
$100

BK 124: The Automatic Stay

The Automatic Stay Injunction Protection. The “automatic stay” is a statutory injunction against efforts outside of bankruptcy to collect debts from a debtor who is under the protection of the bankruptcy court.  Saint Catherine Hospital of Indiana v. Indiana Family and Social Services Admin., 800 F.3d 312, 315 (7th Cir. 2015).  Generally,…
$100

BK 125: Chapter 7 Discharge

Chapter 7 Discharge. The bankruptcy discharge varies depending on the type of case a debtor files: Chapter 7, 11, 12, or 13.  This course’s primary focus is the discharge granted to an individual in a Chapter 7 case. What is a Discharge in Bankruptcy? A bankruptcy discharge releases the debtor from personal…
$100

Bankruptcy Scholar Certificate Exam – 250 Questions

Bankruptcy Scholar Certificate Exam – 250 Questions. So, do you have what it takes to pass the 250-question exam and earn the Bankruptcy Scholar certificate from National Bankruptcy Academy? Start down the path toward being recognized by your peers and prospective clients as a top Chapter 7 consumer bankruptcy attorney…
$99

OIC Scholar Certificate Exam – 650 Questions

Offer in Compromise Scholar Certificate Exam – 650 Questions. So, do you have what it takes to pass the 650-question exam and earn the Offer in Compromise Scholar certificate from National Offer in Compromise Academy? Start down the path toward being recognized by your peers and prospective clients as a…
$99

Intro 102: Statutes, Regulations, Courts & IRM

Statutes, Regulations, Courts & Internal Revenue Manual. Key to understanding tax solutions to IRS back-taxes is an understanding of the interplay between federal statutes, IRS regulations, court rulings, internal revenue manual, revenue rulings, revenue procedures, IRS announcements, and IRS Notices.  This course separately examines each source of tax law. https://youtu.be/hoczX0oVBzI
$99

Intro 103: Understanding the IRS Collection Process

Understanding the IRS Collection Process. https://youtu.be/qn3hMR9pjOk This course provides a brief overview of the IRS collection process.  It does not provide strategies or exceptions to the rule.  Later courses provide a greater explanation of these issues. The collection process starts after a taxpayer files a tax return without full payment…
$99

OIC 101: IRS Authority to Eliminate Back-Taxes

IRS’ Authority, Motivation & Basis to Eliminate Back-Taxes. https://youtu.be/rwKeaiLO9xY An Offer in Compromise is an agreement between a taxpayer and the IRS that settles a tax liability for payment of less than the full amount owed.  IRM § 5.8.1.2.1 (09-23-2008); Adamowicz v. US, 08-888C, Pg. 5 (D.C. Ct. Fed. Cl. 11/21/2011). …
$99

OIC 102: Overview of the OIC Application Process

Overview of the Offer in Compromise Application Process. https://youtu.be/2FIA2Rv94cY This course focuses on a taxpayer’s ability to eliminate past-due federal income tax liability by establishing a repayment plan through the IRS “Offer in Compromise” program, which is commonly known as the “Fresh Start Initiative.”  An overview is presented to help navigate…
$99

OIC 103: Who Submits the OIC Application?

Who is the Proper Party to Submit the OIC Application? https://youtu.be/sW6KfFiK8wo Before filing a formal Offer in Compromise application, a taxpayer may request a meeting in the IRS office which would have jurisdiction over the offer to explore the possibility of compromising unpaid tax liability.  26 C.F.R. § 601.203(d).  The Offer…
$99

OIC 105: Is the OIC Offer “Processable?” – Part 1

Is the OIC Offer Submitted “Processable?” – Part 1. https://youtu.be/RGivexRiG_0 The IRS receives the taxpayer’s offer.  The first step it takes is to determine if the submitted offer is “processable.”  This issue is divided into two separate courses.  Part 1 addresses issue relating to the taxpayer’s ability to fully pay…
$99

OIC 106: Is the OIC Offer “Processable?” – Part 2

Is the OIC Offer Submitted “Processable?” – Part 2. https://youtu.be/RGivexRiG_0 The IRS receives the taxpayer’s offer.  The first step it takes is to determine if the submitted offer is “processable.”  This issue is divided into two separate courses.  Part 1 addresses issue relating to the taxpayer’s ability to fully pay…
$99

OIC 107: Offer Amount Formula

Offer in Compromise Offer Amount Formula. https://youtu.be/U4zEn2bHWC0 The three types of Offer in Compromise are as follows: (a) compromise based on “doubt as to collectibility”; (b) compromise based on “doubt as to liability”; and (c) compromise that promotes effective tax administration.  26 C.F.R. § 301.7122-1(b); Johnson v. Commission of Internal…
$99

OIC 108: Asset Valuation for RCP – Part 1

Asset Component of RCP Formulas – Part 1. https://youtu.be/j2pMb1-OM-4 This Course focuses on Part 1 of the “asset” component of the RCP formulas or “,” including identifying and valuing the taxpayer’s assets.  The “asset” component of the RCP formulas represents the realizable net equity in the taxpayer’s assets.  The realizable…
$99

OIC 109: Asset Valuation for RCP – Part 2

Asset Component of RCP Formulas – Part 2. https://youtu.be/j2pMb1-OM-4 This Course focuses on Part 2 of the “asset” component of the RCP formulas or “,” including identifying and valuing the taxpayer’s assets.  The “asset” component of the RCP formulas represents the realizable net equity in the taxpayer’s assets.  The realizable…
$99

OIC 111: Expense Calculation for RCP, Part 1

Expense Component of RCP Formulas – Part 1. https://youtu.be/OJCnBlwUdu8 This course focuses on Part 1 of the “allowable monthly expenses” component of the “Future Income” calculation for the RCP formulas.  The allowable monthly expense analysis determines the “allowability” of a taxpayer’s monthly expenses.   The next course, Part 2, focuses on…
$99

OIC 112: Expense Calculation for RCP, Part 2

Expense Component of RCP Formulas – Part 2. https://youtu.be/OJCnBlwUdu8 This course focuses on Part 2 of the “allowable monthly expenses” component of the “Future Income” calculation for the RCP formulas.  The allowable monthly expense analysis determines the “allowability” of a taxpayer’s monthly expenses.   The prior course, Part 1, focused on…
$99

OIC 116: Collateral Agreements

Collateral Agreements. Treasury regulation 26 C.F.R. § 301.7122-1(e)(2) states: “As additional consideration for the acceptance of an offer to compromise, the IRS may request that taxpayer enter into any collateral agreement or post any security which is deemed necessary for the protection of the interests of the United States.”  26…
$99

OIC 118: Terminating a Pending Offer

IRS Terminating a Pending Offer. An Offer in Compromise application can be “terminated” while the IRS is considering the application.  A “termination” is defined as a closing of the Offer in Compromise application review process due to the death of the taxpayer.  IRM § 5.8.7.1.6(1) (12-20-2018).  The IRS must terminate its…
$99

OIC 119: Withdrawing a Pending Offer

Taxpayer “Withdrawing” a Pending Offer. An Offer in Compromise application can be “withdrawn” by the taxpayer while the IRS is considering the application.  The withdrawal of an application closes the Offer in Compromise application review process.  There are two kinds of withdrawn offers: voluntary and mandatory.  IRM § 5.8.7.4(1) (09-23-2008).…
$99

OIC 121: Rejecting a Pending Offer

“Rejecting” a Pending Offer. The IRS can “reject” a processable Offer in Compromise application for many reasons.  The IRS defines “reject” as a non-acceptance recommendation of any OIC offer that includes appellate rights.  IRM § 5.8.7.1.6(1) (12-20-2018).  The rejection of an application closes the Offer in Compromise application review process. …
$99

OIC 122: Accepting a Pending Offer

“Accepting” a Pending Offer by the IRS. The decision whether to “accept” an offer to compromise is within the IRS’ discretion and must be based upon consideration of all the facts and circumstances.  26 C.F.R. § 301.7122-1(c)(1); Johnson v. Commission of Internal Revenue, 136 T.C. 475, 485 (2011); Christopher Cross, Inc.…
$99

OIC 126: Appellate Rights

Appellate Rights Relating to OICs. This course discusses appellate rights in the Offer in Compromise context.  Appellate rights are better understood when segregated into three issues: (1) appellate rights relating to a pre-rejection “independent administrative review”; (2) appellate rights following a collection due process determination (i.e.  offer made as part of…
$99

OIC 127: Levy Affected by OIC

Levy Affected by OIC. Taxpayers are not protected from the IRS collection apparatus while contemplating or completing an Offer in Compromise application.  Similarly, taxpayers are not automatically protected from levy by submitting an Offer in Compromise application.  “Submission of an Offer in Compromise does not automatically stay collection of an…
$99

OIC 128: OIC Affects an Installment Agreement

Installment Agreements Affected by OIC. Is a taxpayer required to continue making installment agreement payments if the taxpayer plans on filing an Offer in Compromise?  Yes, is the simple answer because the Offer in Compromise application has not yet been submitted and has not yet been approved for processing by the IRS. …
$99

IA 101: Routine Installment Agreements

Routine Installment Agreements. The Federal government raises money to fund governmental operations through tax revenues collected by the IRS.  Taxpayers are required to voluntarily comply with the Tax Code, including filing returns and paying taxes.  The IRS wants full payment of the tax liability ASAP.  The IRS encourages taxpayers to pay…
$99

IA 102: Levy Protection with Installment Agreements

Levy Protection Afforded by Installment Agreements. Installment agreements are employed to shield taxpayers from the IRS’ dreaded levy apparatus while paying back-taxes through a systematic repayment plan.  The IRS’ most lethal collection weapon is the feared LEVY.  The IRS uses the levy as a sword against taxpayers by seizing taxpayers’ money…
$99

IA 103: Guaranteed Installment Agreements

Guaranteed Installment Agreement. The “Guaranteed” installment agreement program is one of the IRS’ special installment agreement programs.  Other special programs with their own specific criteria discussed elsewhere include “Streamlined” installment agreements, “In-Business Trust Fund Express” installment agreements, and “Partial Payment” installment agreements. As discussed in a previous course, Congress granted…
$99

IA 104: Streamlined Installment Agreements

Streamlined Installment Agreement. The “Streamlined” installment agreement program is another of the IRS’ special installment agreement programs.  Other special programs with their own specific criteria discussed elsewhere include “Guaranteed” installment agreements, “In-Business Trust Fund Express” installment agreements, and “Partial Payment” installment agreements. The “Streamlined” installment agreement program has many helpful…
$99

IA 105: In-Business Trust Fund Express Installment Agreements

In-Business Trust Fund Express Installment Agreement. The “In-Business Trust Fund Express” installment agreement program is another of the IRS’ special installment agreement programs.  Other special programs with their own specific criteria discussed elsewhere include “Guaranteed” installment agreements, “Streamlined” installment agreements, and “Partial Payment” installment agreements. The “In-Business Trust Fund Express” installment agreement…
$99

IA 106: Partial Payment Installment Agreements

Partial Payment Installment Agreements. Is your client unable to pay the back-taxes in full prior to the collection statute expiration date?  Then all installment agreement programs discussed in earlier courses are of no use – because those installment agreements require the taxpayer to fully pay the tax liability prior to…
$99

IA 110: IRS Acceptance & Rejection Determinations

IRS Acceptance & Rejection Determinations. Acceptance or rejection of a proposed “routine” installment agreement is based on analysis of (a) compliance with filing and payment requirements, (b) collection information statements, and (c) taxpayer provided documentation.  As explained in other lessons, special criteria exist for those taxpayers who qualify for Guaranteed,…
$99

IA 111: Terminating & Modifying Existing Agreements

Terminating & Modifying Existing Installment Agreements. Generally, an installment agreement approved by the IRS remains in effect for the stated term of the agreement.  26 U.S.C. § 6159(b)(1).  However, a taxpayer may request that the IRS alter, modify or terminate the terms of the installment agreement because of a change…
$99

IA 112: Appellate Review

Appellate Review. The Tax Code requires the IRS to conduct an “independent administrative review” before the rejection of an installment agreement is communicated to the taxpayer.  26 U.S.C. § 7122(e).  Although the intention to recommend rejection should be relayed to the taxpayer, actual rejection of a proposed agreement must not be…
$99

ISR 101: 3 Types of Relief from Joint and Several Liability

Three Types of Relief from Joint and Several Liability. Many married taxpayers choose to file a joint tax return because of benefits this filing status affords them but ignore the detriments.  When filing jointly, both taxpayers are jointly and severally liable for the tax and any additions to tax, interest, and penalties…
$99

ISR 103: Separation of Liability Relief

Separation of Liability Relief. Congress has authorized “Separation of Liability Relief” for qualifying spouses to relieve them from certain joint and several tax liability related to a tax “deficiency.”  26 U.S.C. § 6015(c).  The Tax Code defines “deficiency,” generally, as the amount by which the tax imposed by IRS Subtitle A…
$99

ISR 104: Equitable Relief

Equitable Tax Relief. Congress has authorized “Equitable Relief” for qualifying spouses to relieve them from certain joint and several tax liability related to a tax deficiency and/or underpayment.  26 U.S.C. § 6015(f).  Equitable Relief also applies to penalties and interest when relief is granted for the underlying item.  IRM § 25.15.12.20.3(5)…
$99

ISR 105: Form 8857, Request for Innocent Spouse Relief

IRS Form 8857, Request for Innocent Spouse Relief. A taxpayer seeks relief from joint and several liability by filing IRS Form 8857, Request for Innocent Spouse Relief.   A Requesting Spouse may seek relief asserting one or more bases.  A Requesting Spouse may submit a single claim (a) electing relief under…
$99

ISR 106: Premature & Untimely Claims

Premature and Untimely Claims. A Requesting Spouse electing Innocent Spouse Relief and/or Separation of Liability Relief or requesting Equitable Relief must be cognizant of the window of opportunity.  Elections and requests can neither be made prematurely nor untimely.  Premature claims are discussed first, followed by a discussion of what constitutes…
$99

ISR 107: Appellate Review

Appellate Review. This course discusses a Requesting Spouse’s appellate rights both (a) when the IRS fails to issue a “preliminary” determination within six (6) months of the election for Innocent Spouse Relief and/or Separation of Liability Relief, or request for Equitable Relief, and (b) after an IRS determination denying the…
$99

ISR 108: Participation by Non-Requesting Spouse

Non-Requesting Spouse’s Participation. Conflict between the Requesting Spouse and the Non-Requesting Spouse is almost inevitable.  Afterall, the Requesting Spouse is attempting to shift the joint and several tax burden onto the sole shoulders of the Non-Requesting Spouse.  This burden shift request can make the Requesting Spouse unpopular in the eyes of…
$99

ISR 109: Levies, Seizure & Court Proceedings Restricted

Levies, Seizure & Court Proceedings Restricted. The IRS’s ability to collect back-taxes is restricted when a Requesting Spouse files a claim with the IRS for Innocent Spouse Relief, Separation of Liability Relief, or Equitable Relief.
$99

ISR 110: Installment Agreements

Installment Agreement Affected by Request for Relief. Some taxpayers do not know their tax options and contact the IRS for an installment agreement after receiving notice from the IRS that an audit revealed a tax deficiency due to a spouse’s failure to report income or improper deduction claim.  This could be a…
$99

ISR 111: Refund Claims

Refund Claims Made by an Innocent Spouse. The Requesting Spouse seeking relief from joint and several liability must be able to distinguish between civil claims for tax refunds and civil actions for tax refunds.  Civil claims for tax refund are made administratively with the IRS utilizing IRS Form 8857.  Civil…
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