The Internal Revenue Service (IRS) has opened a limited-time settlement initiative for taxpayers in Georgia and nationwide involved in syndicated conservation easement partnerships. The initiative focuses on cases still under IRS audit or already filed in U.S. Tax Court, where earlier offers expired or were rejected. Partnerships may join if they get an official IRS settlement letter or receive approval after a case-by-case review.
If you find yourself in this situation, settling within the first 90 days of this initiative can mean qualifying for the best conditions available. Understanding the importance of this timeframe is key to resolving long-running audits and disputes without facing years of litigation.
The significance of the window
To get the most favorable settlement terms, it is vital for you to act within the initial 90-day window. This includes:
- 0% allowed charitable deduction
- 10% reduced penalties
- No upfront full payment required at acceptance
Waiting past the 90th day can cause the penalties to increase significantly, generally to 20%. Once this initiative expires, the IRS intends to pursue full penalties and litigation.
Tax advantages for Georgia residents
Settling with the IRS also creates an immediate opportunity to potentially resolve your Georgia state tax issues. Utilizing the Georgia Voluntary Disclosure Program (VDP) can often help qualifying taxpayers pay zero state penalties.
Under VDP, the state typically only looks back three years instead of the usual five or six. This can save you significant time and money.
Strategic moves while your case is pending
Your lawyer can help you make purposeful cash deposits with the IRS to reduce the amount of interest that keeps growing on your tax debt. They can guide you through the process while reviewing your settlement options. These deposits can help stop your balance from increasing and possibly lower the overall cost of what you have to pay in the end while your case is being processed.
Avoiding the malpractice pitfall
Conservation easement law is a high-stakes intersection of partnership tax, tax procedure and individual income tax. Many general-practice certified public accountants (CPAs) or advisors are not equipped to handle these specific assessments.
Attempting to navigate this without experienced tax litigation counsel can potentially lead to missed deadlines and costly errors. The team at Bomar Law Firm LLC can help protect your assets and put this audit behind you before the 90-day window closes.
