TOUGH IRS POLICIES ON REPEATER EMPLOYMENT TAX LIABILITIES

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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 ]

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