Yearly Archives: 2025

Did you know that owing the IRS can put your passport at risk? That’s exactly what happened to Drew Pfirrman, a Florida resident who recently lost his Tax Court case after the IRS certified his “seriously delinquent tax debt.”

What Happened?

·         Unreported Income: The IRS found Pfirrman had over $367,000 in unreported income for 2018 and hit him with a six-figure tax bill, penalties, and interest.

·         IRS Notices Ignored: He missed his chance to challenge the debt through the proper IRS channels.

·         Passport in Jeopardy: When his tax debt grew to over $182,000, the IRS notified the State Department, threatening his passport.

Can You Fight It?

Pfirrman tried to argue that his debt was lower and that partial payments should help. But the Tax Court ruled it can’t reconsider the original tax bill in a passport case. Only full payment of the debt (or qualifying for a special exception) can get your passport privileges restored.

The Lesson

Don’t ignore IRS notices. If you owe big, act fast-set up a payment plan or pay in full. Once the IRS certifies your debt, it’s too late to argue about the amount in court, and your travel plans could be grounded. 

See also our post TC Determines That Taxpayer's Debt Was 'Seriously Delinquent' Even after He Paid Tax to Reduce Balance below $50,000 where we discussed that once a certification of a seriously delinquent tax debt has been made, it may be reversed "if the debt with respect to such certification is fully satisfied." I.R.C§ 7345(c)(1) (emphasis added).

If You Have Serious Delinquent IRS Debt, You Should Consult with Experienced Tax Attorneys, As There Are Several Ways Taxpayers Can Avoid Having the IRS Request That the State Department Revoke Your Passport. 

  Want To Keep Your US Passport?
 

 

Contact the Tax Lawyers at 

Marini & Associates, P.A.

for a FREE Tax Consultation Contact us at:

www.TaxAid.com or www.OVDPLaw.com 

or Toll Free at 888-8TaxAid (888)882-9243.

References

1.       https://www.currentfederaltaxdevelopments.com/blog/2025/3/18/irs-properly-certified-seriously-delinquent-tax-debt-to-state-department-leading-to-potential-loss-of-passport             

2.      https://www.thetaxadviser.com/issues/2025/mar/certification-of-seriously-delinquent-tax-debt-not-erroneous/           

3.      https://www.leagle.com/decision/intco20250318g64  

4.      https://www.irs.gov/pub/irs-access/p5827_accessible.pdf   

5.       https://www.irs.gov/businesses/small-businesses-self-employed/revocation-or-denial-of-passport-in-cases-of-certain-unpaid-taxes 

Read more at: Tax Times blog

The IRS Independent Office of Appeals, led by Chief Liz Askey since last year, is currently navigating significant workforce challenges. At the start of the calendar year, Appeals had about 1,777 employees. However, the office is experiencing notable attrition:

·         Approximately 77 probationary employees are on administrative leave and unable to work.

·         Over 300 employees have signed deferred resignation agreements, with another 100 pending.

·         A substantial portion (43%) of staff are retirement-eligible or early retirement-eligible, contributing to the high number of departures.

As a result, Askey projects that by the end of the current fiscal year, the Appeals workforce will be reduced to around 1,324 employees. Compounding these losses, the office is under a hiring freeze for both internal and external candidates. Askey anticipates that after current workforce reduction and reshaping efforts conclude, Appeals may be able to hire from the IRS compliance function to address short-staffing.

Summary Table: IRS Independent Office of Appeals-Current State

Case Cycle Times: Progress Despite Constraints

Despite these staffing reductions and hiring limitations, Appeals has made measurable progress in reducing case cycle times:

·         The average cycle time for non-docketed cases in fiscal year 2025 is now 274 days, the lowest level in six years.

·         This is a significant improvement from the 2022 National Taxpayer Advocate report, which cited a 365-day average for non-docketed cases-a 103% increase over 2017 cycle times.

·         Askey attributes this improvement to targeted efforts, including analyzing and reducing delays in getting cases to Appeals and implementing a "paperless pilot" for scanning smaller case files upon receipt, streamlining case handling.

Askey remains "cautiously optimistic" that these trends will continue, even as workforce changes persist.

Conference Options: In-Person, Virtual, and Hybrid

Appeals offers taxpayers several ways to resolve disputes, including:

·         In-person conferences

·         Telephone conferences

·         Video conferences (using Microsoft Teams)

·         Correspondence or secure messaging

The office has a longstanding policy of accommodating taxpayer preferences for conference format, especially for larger and more complex cases. While there was a temporary shift to virtual conferences due to recent travel policy changes, a new travel approval process is now in place. Appeals Officers can again travel for in-person conferences, though more lead time is required for approval.

For taxpayers not near an Appeals office, the office continues to use "circuit riding," where Appeals Officers travel to more convenient locations, and is seeking public input on improving accessibility and hybrid conference options.

Have an IRS Tax Problem?

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

References:

1.       https://www.irs.gov/appeals/what-to-expect-from-the-independent-office-of-appeals  

2.      https://www.irs.gov/newsroom/improving-nationwide-access-to-irs-appeals-public-input-wanted    

3.      https://www.irs.gov/appeals/appeals-expands-access-to-video-conferences 

4.    https://irstaxtrouble.com/irs-appeals-guidance-on-in-person-conferences/

Read more at: Tax Times blog

According to the DoJ, he U.S. District Court for the Southern District of Florida issued an injunction on April 28, 2025 against Miami tax return preparer Nia Daniel, which bars her from preparing tax returns for others, having any ownership stake in any tax preparation business, or assisting or training others in tax return preparation through at least Jan. 27, 2028. The court also ordered Daniel to disgorge $446,000 in ill-gotten gains she received from her return preparation business. Daniel agreed to both the injunction and ordered disgorgement.

The complaint alleged that Daniel understated customers’ tax liability and claimed inflated refunds largely by:

• Falsifying or overstating business expenses claimed on a Schedule C;
• Claiming the Work Opportunity Tax Credit for clients who did not qualify for it;
• Falsely claiming other credits, such as the American Opportunity Credit and Residential Energy Credit; and
• Falsifying income and filing status to increase the Earned Income Tax Credit.

According to the complaint, the IRS estimated a tax loss of more than $500,000 in 2023 alone from returns prepared by Daniel. 

The DoJ also did a press release regarding an Accountant Who Pleads Guilty to $8M Tax Fraud where they discussed that A Colorado man pleaded guilty on April 28, 2025 to conspiring to defraud the United States and tax evasion.

According to court documents and statements made in court, Rodney Ermel owned and managed a Colorado-based accounting firm. 

Along with co-defendant Kenneth Bacon, Ermel provided accounting and tax preparation services for Joseph LaForte and his entities. Ermel conspired with LaForte, Bacon, and others to hide approximately $20 million in income. 

He did this through various fraudulent accounting practices, such as fabricating shareholder loans and “bad debt” deductions. Ermel also filed tax returns which he knew underreported taxable income by over $20 million between 2016 and 2018. Ermel’s fraud caused a loss to the United States of over $8 million.

Ermel is the fourth defendant to plead guilty to criminal conduct related to this tax scheme.  Sentencing is scheduled for Sept. 3.

Have an IRS Tax Problem?

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Read more at: Tax Times blog

• You Are Tired of Trump 2.0.
• That The Republicans Now Control the House & the Senate.
• Are You Sick of Liberal Democrats Trying to Revise Society or
• Maybe You're A Naturalized U.S. Citizen Or Permanent Resident Who Has Prospered Here, But Would Now Like To Move Back The Old Country For Retirement or toStart A New Venture?

You Might Want to Consider Expatriation?

The Internal Revenue Service said in its notice that the number of people who expatriated from the U.S. increased nearly 24% during the third quarter of 2024 compared with the previous quarter. 

The Number Of People Losing Or Renouncing Their U.S. Citizenship Increased to 1,278 For the 1st Qtr of 2025.

A 200% Increase From The 4th Quarter of 2024.

Included on the list are those who lost U.S. citizenship under Internal Revenue Code Section 877(a) and Section 877A, according to the notice, as well as long-term residents who are treated as losing citizenship under Section 877(e)(2).

According to CNBC the top reason why Americans abroad want to dump their U.S. citizenship include:

• Nearly 1 in 4 American expatriates say they are “seriously considering” or “planning” to ditch their U.S. citizenship, a survey from Greenback Expat Tax Services finds.  
• About 9 million U.S. citizens are living abroad, the U.S. Department of State estimates.
• More than 4 in 10 who would renounce citizenship say it’s due to the burden of filing U.S. taxes, the Greenback poll shows.

Should I Stay or Should I Go?

Need Advise on Expatriation?

 

Contact the Tax Lawyers at 

Marini & Associates, P.A.   

for a FREE Tax Consultation contact us at:

www.TaxAid.com or www.OVDPLaw.com 
or Toll Free at 888-8TaxAid (888) 882-9243

Read more at: Tax Times blog