April 13, 2020
Mary Lee Miller EA, LLC
During the COVID-19 pandemic, the last thing you need is the IRS
doing bad things, like auditing you or levying your bank account or
wages.
But don’t worry—the IRS is pausing most of its collection and audit
enforcement actions.
Installment Agreements
If you have an installment agreement with the IRS, then the IRS is
suspending your payments due between April 1 and July 15, 2020.
The IRS will not default any installment agreements during this period.
Remember—interest will continue to accrue on any unpaid
balances, so if you have the financial resources, you may
want to continue to pay.
Offers in Compromise
If you have a pending offer in compromise, then the IRS will allow
you until July 15, 2020, to provide requested additional information
to support your offer. The IRS will not close any pending offer in
compromise requests before July 15, 2020, without your consent.
If the IRS has accepted your offer in compromise, then you can
suspend all payments toward it until July 15, 2020.
The IRS won’t default your accepted offer in compromise for a
failure to file your 2018 tax return. But you should file your
delinquent 2018 return (and your 2019 return) on or before
July 15, 2020, to avoid default.
Collection Actions
IRS field revenue officers won’t initiate liens and levies
(including any seizures of personal residences) through
July 15, 2020; however, they will continue to pursue high-income
non-filers and perform other similar activities as needed.
In addition, consider the following actions:
• The IRS won’t initiate new automatic, computer-generated
liens and levies through July 15, 2020.
• The IRS will suspend new certifications to the Department of
State for taxpayers who have “seriously delinquent” tax debt
through July 15, 2020. Certification prevents you from receiving
or renewing a passport. If your tax debts are subject to certification;
you should submit a request for an installment agreement, an offer
in compromise, or another collection alternative, prior to
July 15, 2020.
• The IRS won’t send new delinquent accounts to private collection
agencies through July 15, 2020.
Audits
The IRS generally will not start new field, office, or correspondence
examinations through July 15, 2020. But it may start new
examinations where deemed necessary to protect the
government’s interest in preserving the applicable statute of
limitations.
The IRS suspended all in-person meetings regarding current
field, office, and correspondence audits. Existing audits will
continue remotely, where possible. You should continue to
respond to any requests for information
you’ve received if you are able to do so.
What if you are ready, willing, and able to get your audit
started? The IRS may agree to begin the audit before
July 15, 2020, if it has personnel available.
Independent Office of Appeals
If you have a case in the Independent Office of Appeals,
then Appeals employees will continue to work your
case. You should promptly respond to any new or
existing requests for information.
Takeaways
If you have IRS problems, the COVID-19 pandemic is creating
a mercy period for you that ends July 15, 2020. During the
mercy period, the IRS is suspending
• installment agreement payments,
• new levies and liens,
• new audits,
• new passport actions, and
• new referrals to private debt collectors.
Use this break in IRS enforcement through July 15, 2020,
as a great opportunity to get back on track and solve
any existing IRS tax problems you have, such as
• completing and sending in those unfiled tax returns;
• getting an installment agreement in place for your unpaid debts;
• requesting an offer in compromise for tax debt you will not be able to pay.