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C-Corp had old payroll tax debt forgiven (CSED - collection statute expiration date). Is that taxable? Or not? Is it even forgiven or is it still owed but the IRS can't collect?
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if a 941 was filed the IRS has 3 years from the time the 941 was filed to assess the tax penalty. Did your client ever file the 941
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Unless the corporation is insolvent, I don't see why it would not be taxable.
The more I know the more I don’t know.
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Cash or accrual basis taxpayer? What type of payroll taxes? Trust fund taxes would likely have been deducted in the prior year as salaries & wages. Employer taxes, maybe or maybe not. If it was written off in a prior year then it should probably be written back on (pending insolvency calculation).
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For an "on the one hand this but on the other hand that" discussion, see
I wonder how many solvent corporations the IRS is allowing off the hook without enforced collection before the statute expires. Also, are you sure it has expired? Who told you?
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Accrual. A bit of 940, but also 941. There was an installment agreement.
Thanks for responding!
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Interesting citation. There was an installment agreement and the annual statement shows the balances being removed due to CSED.
Thanks for your response!
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Got it, thank you!
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Yes, 941s were filed. This wasn't a 941 penalty, it was the 941 taxes themselves.
Thanks.
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Thanks for the response, much appreciated!