This taxpayer solution is often overlooked. This solution is normally used when a taxpayer and/or representative have attempted to solve the tax problem with IRS Automated Collections (ACS) and/or with IRS Tax Practitioners Hotline (TPH) without any positive results. In other words, all known solutions have been attempted without positive results. When to use:
* The taxpayer is experiencing economic harm or is about to suffer economic harm.
* The taxpayer is facing the immediate threat of adverse action.
* The taxpayer will incur significant costs if relief is not granted (including fees for professional representation).
* The taxpayer will suffer irreparable injury or long-term adverse impact if relief is not granted.
* The taxpayer has experienced a delay of more than 30 days to resolve a tax account problem.
* The taxpayer did not receive a response or resolution to their problem or inquiry by the date promised.
* A system or procedure has either failed to operate as intended or failed to resolve the taxpayer’s problem or dispute within the IRS.
* The manner in which the tax laws are being administered raise considerations of equity or have impaired or will impair the taxpayer’s rights.