Form 4810 Request for Prompt Assessment

[Strongsilence-CPA]

A 4810 was filed in January 2021.  The RPA reduces the time for assessment from 3 years to 18 months. Now, in June 2022, we have no indication that the IRS ever received it. There was a delay due to the death of a primary trustee, but we complied by sending all necessary documents to prove the authority of the successor trustee to three different IRS units.  Therefore, the RPA has done nothing for the client.  And closing the estate will also be delayed.

[sjrcpa]

Sorry to hear this. Sadly, this is typical of IRS.

I haven't requested prompt assessment in a while because my experience showed they just ignored it.

[Strongsilence-CPA]

Thanks for listing SJR.  There are 3 IRS units (maybe 4) working on this and no one has explained the problem with our application. I am requesting the help of the Taxpayer Advocate.  

[BobKamman · Accepted solution]

The Taxpayer Advocate paychecks are signed by the same guy who signs the checks for the other IRS units you are dealing with.  Mostly it's a publicity stunt.  But where does it say IRS has to issue a clearance letter?  Isn't Section 6501(d) self-executing, like any other statute of limitations?  I agree with @sjrcpa.  The Form 4810 is like waving a red flag, a tale told by an idiot, full of sound and fury,  signifying nothing.  As Macbeth might have said.  

[Strongsilence-CPA]

Thanks Bob.

The attorneys wanted the 4810 because the trustee is very, very worried about personal liability.  This estate has very little exposure, but the trustee is very anxious.  Had I talked with you, and had I known that the pandemic would discombobulate IRS operations, and had I been able to convince the parties that the risk of tax is nearly non-existent, I would not have filed it.

There is an amount of money in reserve.  The attorney and I thought a prompt assessment would allow the reserve to be paid out sooner.