by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily
A taxpayer who filed jointly in 2018, 2019, or earlier years may now find that the former spouse is divorced, separated, deported, deceased, or otherwise unavailable to provide a signature on a joint protective filing. The procedural question is whether the taxpayer...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily
A protective Form 843 packet that does not identify the affected transcript entries is procedurally weak. The Treas. Reg. § 301.6402-2(b)(2) sufficiency requirements call for the grounds of the claim to be identified with enough specificity that the IRS examiner can...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily
The Court of Federal Claims decided Kwong v. United States, 179 Fed. Cl. 382 (Fed. Cl. 2025), in a way that reopened a calendar most taxpayers and practitioners assumed had closed. The court read former IRC § 7508A(d), the federally declared disaster provision in...
by Noah Green CPA CFE | May 17, 2026 | Sheepdog Tax Resolution Daily
A protective claim is a procedural posture, not a separate document type. The vehicle for a Kwong v. United States protective claim, penalties and interest assessed off original (pre-postponement) due dates falling inside the COVID disaster window, is Form 843, the...
by Noah Green CPA CFE | May 16, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
Discovering omitted income on a filed return is not, by itself, a crisis. It is a decision point. The right next step depends on what kind of income was missed, what year it covers, whether the IRS or the state has already noticed, how the omission affects the...
by Noah Green CPA CFE | May 16, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
IRS Form 1040-X is the individual amended-return form. It is used to correct a filed Form 1040, 1040-SR, or 1040-NR when the taxpayer’s filing status, income, deductions, credits, dependents, or tax liability changed. In a tax-resolution case, the harder...
by Noah Green CPA CFE | May 6, 2026 | Installment Agreements, IRS Collections & Payment Plans
If your IRS installment agreement has already terminated, either because the 30-day window on a CP523 expired or because the IRS confirmed termination after a default, you are not out of options. Reinstatement is still possible. So is renegotiating into a new...
by Noah Green CPA CFE | Apr 30, 2026 | Behind the IRS Curtain, IRS Notices
Thread: A (Behind the IRS Curtain) A tax-resolution practitioner notices the same thing every September: the firm’s phone volume doubles. Clients who have been quiet for months suddenly call in a single week saying “I got a letter from the IRS.”...
by Noah Green CPA CFE | Apr 29, 2026 | Installment Agreements, Trust Fund Recovery
If your business received an IRS Notice CP523 on a Form 941 payroll tax installment agreement, you are not in the same procedural position as an individual taxpayer with the same notice. Business payroll tax cases, particularly those involving trust fund liabilities...
by Noah Green CPA CFE | Apr 23, 2026 | Behind the IRS Curtain, IRS Collections & Payment Plans
Thread: A (Behind the IRS Curtain) A restaurant owner has been carrying a $180,000 payroll tax balance for two years. His case bounced around the IRS Automated Collection System for the first eighteen months and then moved into Field Collection. The new contact is a...
