Office of Chief Counsel 360x1000
Samuel Johnson 360x1000
Mary Ann Evans 360x1000
Tad Friend 360x1000
2albion
1defense
James Gould Cozzens 360x1000
1paradide
14albion
Margaret Fuller3 360x1000
3theleastofus
1transcendentalist
Margaret Fuller 360x1000
2defense
1jesusandjohnwayne
11albion
Betty Friedan 360x1000
Margaret Fuller4 360x1000
7albion
9albion
Brendan Beehan 360x1000
storyparadox3
11632
6albion
1madoff
Spottswood William Robinson 360x1000
Margaret Fuller 2 360x1000
Lafayette and Jefferson 360x1000
199
1albion
1trap
Mark V Holmes 360x1000
Anthony McCann1 360x1000
1falsewitness
2lookingforthegoodwar
Margaret Fuller2 360x1000
3defense
Maurice B Foley 360x1000
13albion
1gucci
Maria Popova 360x1000
2confidencegames
2trap
2paradise
LillianFaderman
lifeinmiddlemarch2
Margaret Fuller1 360x1000
299
Gilgamesh 360x1000
2falsewitness
storyparadox2
399
1confidencegames
Anthony McCann2 360x1000
Ruth Bader Ginsburg 360x1000
8albion'
AlexRosenberg
12albion
Thomas Piketty1 360x1000
Adam Gopnik 360x1000
499
Susie King Taylor 360x1000
5confidencegames
1empireofpain
2jesusandjohnwayne
4confidencegames
Thomas Piketty2 360x1000
2lafayette
6confidencegames
3confidencegames
1theleasofus
1lafayette
2theleastofus
3paradise
3albion
George F Wil...360x1000
2transadentilist
Stormy Daniels 360x1000
lifeinmiddlemarch1
George M Cohan and Lerarned Hand 360x1000
Learned Hand 360x1000
Susie King Taylor2 360x1000
2gucci
Margaret Fuller5 360x1000
Storyparadox1
Richard Posner 360x1000
1lookingforthegoodwar
7confidencegames
Edmund Burke 360x1000
Thomas Piketty3 360x1000
1lauber
4albion
10abion
5albion

One of the favorite sayings of my first managing partner the late Herb Cohan was “I’d rather owe it to you than cheat you out of it.” To be honest, like some of the other sayings, it was never clear exactly what it meant.  Nonetheless, I think it sums up pretty well a tax strategy that is becoming more viable every year.  File a timely accurate return and just don’t pay.  Wait ten years and celebrate when the statute of limitation on collections runs out.

The Big Picture

In a piece last month – IRS Collections Appears To Be Broken –  I went over some of the numbers that indicate this strategy is a thing.  Most notably in the fiscal year ended September 30, 2019 the IRS wrote off $34.2 billion because of the ten year statute. That is more than double the $14.6 billion IRS wrote off in the 2010 fiscal year.  Keep in mind that this is assessed tax, interest and penalties.  It has nothing to do with taxes that were avoided by not filing or engaging in shenanigans on the return.

Although I have some reports from people who have the 10 year statute work for them, I have not, until this month, heard from somebody who plans on it.  He insisted that I protect his identity, so I am going to call them Henry, which I will explain later.  Henry is not his or her real name, unless it is.


This article is available on Think Outside The Tax Box. 

Think Outside the Tax Box