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IRS CP523 Notice: 12 Questions Answered

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...

The “Wealth Squad”, IRS’s quiet high-net-worth audit team explained

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...

IRS CP523 Notice: Your 30-Day Action Plan to Save Your Installment Agreement

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...

Reasonable Collection Potential: The Calculation Walk-Through

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 ×...

Why the IRS audits some industries way more than others, the National Research Program decoded

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...

CDP Notice of Determination + the Tax Court §6330(d) Appeal Path

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...

The IRS Collection Notice Ladder: CP14 → CP501 → CP503 → CP504 → LT11

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...

Form 433-A vs 433-B vs 433-F: When Each Is Required

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 /...

What happens inside the IRS when a return gets flagged, the 14-day journey from filing to follow-up

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...

Equivalent Hearing vs CDP: The Procedural Difference That Matters

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)...
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