Procedural Issues
Calling Bullshit on the Government

Procedural Considerations on Collection (Levies and Distraints) – Part One: Introduction to Levies

On Levies and Distraints To Bill’s credit, his call of the IRS’s bluff that they would actually try to collect his long delinquent tax debt has not resulted in any enforced collection action three years since he failed to report capital gains on the sale of seven of his largest ostriches.  You had no love loss when the giant birds were sold, having been chased down and assaulted by two of their number in your

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Scott St. Amand April 29, 2021
Procedural Issues
Calling Bullshit on the Government

Can the IRS be Bound by State Statutes of Limitation?

The IRS is not shy when it comes to flexing its Federal muscles. In a 2001 Chief Counsel Advice Memorandum, rather like a bodybuilder at the beach, the IRS so flexed (observed): The federal government is not barred by any state statute of limitation periods (or otherwise labeled claim extinguishment provisions) from enforcing its rights under the Internal Revenue Code to assess or collect taxes, even though the federal government may be relying on state

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Scott St. Amand April 29, 2021
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Can the IRS be Bound by State Statutes of Limitation?

The IRS is not shy when it comes to flexing its Federal muscles. In a 2001 Chief Counsel Advice Memorandum, rather like a bodybuilder at the beach, the IRS so flexed (observed): The federal government is not barred by any state statute of limitation periods (or otherwise labeled claim extinguishment

Read More »
Scott St. Amand April 29, 2021