In Uncategorized on 03/13/2018 at 15:23

It was a truism from the most verdant of my salad days, that upon hearing those words, one should stand up, check equipment, hook up, stand in the jump door and jump. Yelling “Geronimo!” was optional; bailing out was not.

Judge Buch echoes this old chestnut today in Patricia Guzik, Docket No. 26364-16L, filed 3/13/18.

One paragraph from this designated hitter will suffice to prove, once again, the truth of the truism.

“Ms. Guzik had three different attorneys during the 14 or so months that the settlement officer conducted her hearing. At nearly every stage her attorneys requested extensions of time to complete necessary paperwork. Each time the settlement officer granted reasonable extensions. Even with all of those extensions, Ms. Guzik did not submit an installment agreement proposal. The settlement officer cannot be forced to propose a collection alternative for a taxpayer who refuses to do so.” Order, at p. 7.

Guess whom the petitioner will blame. No prize for the correct answer.

  1. Reily’s Second Law of Tax Practice

    *When The Prospect Tells You His Last Two Accountants Were Assholes It Won’t Be Long Before You Become The Next Asshole*

    That is what your title made me think of.


  2. Mr Reilly, I am sure it’s universal.


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