Client Situation: Patricia, a small business owner operating a catering company in New Jersey, received Letter 1058 in March 2025 when a Revenue Officer hand-delivered it during a visit to her business. She owed $87,000 in combined income tax and payroll tax from 2021-2023. The Revenue Officer had already visited twice — once to inspect the business and once to deliver the letter. Patricia had 26 days remaining on her CDP deadline when she called Global Gate.
The Challenge: Patricia’s catering business was profitable but seasonal, with tight margins and significant monthly expenses (commercial kitchen lease, staff, insurance, food costs). She couldn’t afford to pay $87,000 or even make large monthly payments. The Revenue Officer had already begun assessing her assets — including commercial equipment worth approximately $35,000.
Global Gate’s Approach: 1. Immediate Power of Attorney (Form 2848) — Filed within 24 hours, stopping all direct Revenue Officer contact with Patricia. 2. Emergency CDP hearing request (Form 12153) — Filed within 48 hours, with 24 days to spare. All levy and seizure activity suspended. 3. Comprehensive financial analysis — We prepared Form 433-A and 433-B showing Patricia’s personal and business finances. Her reasonable collection potential (RCP) calculated to approximately $19,000 based on limited equity in assets and minimal disposable income after necessary business expenses. 4. Offer in Compromise submission — We submitted an OIC for $19,000 as part of the CDP hearing — approximately 22 cents on the dollar. 5. Revenue Officer management — During the OIC review, we maintained communication with both the Appeals Officer and the Revenue Officer’s manager to ensure no unauthorized collection actions were taken. 6. OIC accepted — After 10 months of review, the IRS accepted Patricia’s Offer in Compromise for $19,000, payable over 24 months at $792/month.
Result: Patricia settled $87,000 in tax liability for $19,000 — a 78% reduction. Her business continued operating without interruption. No assets were seized. No bank levy or wage garnishment was issued. The Revenue Officer’s case was closed upon OIC acceptance.
Key Takeaway: The Revenue Officer had the authority and intent to seize Patricia’s commercial equipment — equipment worth $35,000 that was essential to running her business. Filing the CDP hearing within the 30-day window prevented that seizure and gave us the time to negotiate a settlement that saved Patricia’s livelihood. Without professional representation, the outcome would have been dramatically different.