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ROBERT E. MCKENZIE, ESQ.

ARNSTEIN & LEHR


120 SOUTH RIVERSIDE PLAZA, SUITE 1200
CHICAGO, IL 60606
312-876-6927
312-876-7318 fax

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TOUGH IRS POLICIES ON REPEATER EMPLOYMENT TAX


LIABILITIES

Repeater Cases

The Internal Revenue Manual provides the following guidelines for negotiating with in-business repeaters:

"... if taxpayers:

• are in business,

• are currently pyramiding trust fund taxes, and

• have three or more trust fund bal dues assigned to the collection field function, then, they are considered
"repeaters." These taxpayers may not -- immediately -- be granted installment agreements.

If, however, after contact, taxpayers originally classified as repeaters:

• do not continue to accrue liabilities; and,

• begin making FTDs; and,

• file all appropriate returns (so that they are in compliance with all filing requirements); then, they are no
longer considered repeaters and may qualify for installment agreements." [IRM 5.14.7.2 ]

COPYRIGHT 2003 ROBERT E. MCKENZIE


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Page created by: remckenzie@arnstein.com


Changes last made on:02/15/2003