Can be automatically approved if under $10,000 Financial statement (Form 433) required if liability over $25,000 IA Terms:
Make payments on time Be up to date on filing your returns
Grounds
Automatic Stay Bankruptcy does not stop IRS from assessing taxes
Transferee Liability
Heirs and Gift Recipients Successors in Interest Certain Fiduciaries The transferee is held liable for the debt of the previous owner, but no fraud is alleged in the transfer of the asset
Two-year rule for requesting relief under 6015(b) or (c) Certain cases can be appealed to Tax Court or a refund court
Relief can be requested in exam or during collection Relief requests halt many collection actions but not all
Transferee Liability Determination Suit Fraudulent Conveyance Suits Suits for Failure to Obey a Levy Erroneous Refund Suits