by Noah Green CPA CFE | Apr 22, 2026 | Installment Agreements, IRS Notices
If you’ve received an IRS Notice CP523, you probably have more questions than answers. This guide walks the 12 most common CP523 questions, what the notice means, what the deadlines control, and what your options look like in week one and week four. Free Guide...
by Noah Green CPA CFE | Apr 16, 2026 | Behind the IRS Curtain
Thread: A (Behind the IRS Curtain) A founder who exited her company in 2019 receives an IRS letter in 2024. The letter doesn’t look like an audit notice from a few years earlier, it doesn’t reference a single tax year, it references three; it doesn’t...
by Noah Green CPA CFE | Apr 15, 2026 | Installment Agreements, IRS Notices
If an IRS Notice CP523 just landed in your mailbox, you have 30 days before your installment agreement officially terminates, and before the IRS gains the right to levy your bank accounts and wages. Free Guide CP523 Survival Guide: try to save your installment...
by Noah Green CPA CFE | Apr 11, 2026 | Offer in Compromise, Sheepdog Tax Resolution Daily
Reasonable Collection Potential is simple in form and difficult in valuation judgment, and the disputes that determine offer acceptance are almost always upward examiner adjustments to taxpayer-side computations. RCP = Net Realizable Equity in Assets + Future Income ×...
by Noah Green CPA CFE | Apr 9, 2026 | Behind the IRS Curtain
Thread: A (Behind the IRS Curtain) A general contractor with $400,000 in Schedule C gross receipts and a software consultant with $400,000 in Schedule C gross receipts file roughly comparable returns in roughly comparable years. The contractor has a meaningfully...
by Noah Green CPA CFE | Apr 9, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
The Notice of Determination is the document that closes a Collection Due Process hearing. It articulates Appeals’ decision on the issues raised at the hearing, collection alternative, lien withdrawal, levy release, underlying liability where...
by Noah Green CPA CFE | Apr 7, 2026 | IRS Notices, Sheepdog Tax Resolution Daily
A taxpayer who files a return showing tax due but does not pay enters a predictable five-stage notice sequence over the next several months. Each notice carries distinct legal consequences, distinct response options, and a distinct procedural status. Treating the...
by Noah Green CPA CFE | Apr 4, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
The form choice is not the taxpayer’s preference, it is determined by the collection function handling the case, by the type of taxpayer, and by the program being pursued. The fast answer for most situations fits in four rows: Case postureForm ACS / individual /...
by Noah Green CPA CFE | Apr 2, 2026 | Behind the IRS Curtain
Thread: A (Behind the IRS Curtain) A small-business owner files her return on a Thursday afternoon in March. By Friday morning she has the IRS e-file acceptance email. By Friday evening she is checking the “Where’s My Refund?” tracker on her phone...
by Noah Green CPA CFE | Apr 2, 2026 | Sheepdog Tax Resolution Daily, Tax Resolution
Both procedures put a taxpayer in front of the same IRS Independent Office of Appeals officer pool. Both use the same Form 12153. Both can raise the same categories of issues, collection alternatives, spousal defenses, procedural defects, and (in narrow circumstances)...