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 | 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 | 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)...
by Noah Green CPA CFE | Mar 31, 2026 | Sheepdog Tax Resolution Daily
A Notice of Federal Tax Lien filing (Letter 3172), a Final Notice of Intent to Levy (LT11 / Letter 1058), or a CP90 opens a 30-day window the Internal Revenue Code defines precisely. Within those 30 days, the taxpayer may file Form 12153 to request a Collection Due...
