Recently, we had an annoying encounter with the IRS. They had decided we'd not paid sufficient 941 funds from 2008, and insisted on billing us over $7000 in penulties and interest. At least that is what we assume they were moaning about, because they had unilaterally changed our address & all the initial notices were lost. We finally recieved the Lien notice, thanks, presumably, to the diligence of a post office clerk, which contained just the total lien with no further explanation.
What should have been simple to sort out became a nightmare. An agent refused to deal with us because (you can see this one coming) our address didn't match their address on record. The 30 day limit expired and we were obliged to sign a waiver to the SOL. It was only with the (excellent) help of the taxpayer's advocate that the matter was finally resolved, although we've yet to see the several thousand in confiscated refund checks they'd trousered over the last 7 months, nor the interest they say they will pay us for our trouble.
Now I'm prepared to accept this as a cost of doing business & put down the address change nonsense to their legendary efficiency. But exactly the same thing has just happened to a friend of mine, except that the $5K they claim he owes is due to some other (invented) filing irregularity.
The common thread seems to be
1) Wait until just before the SOL expires to maximize penulties and interest.
2) Pick an amount which is just on the cusp of being worth fighting in tax court, due to a supposed filing anomaly
3) Send notices to the wrong address, maximizing the chance that a Lien can be filed without the taxpayer noticing.
4) Refuse to discuss the matter because the address doesn't match their records.
Any CPAs here seen anything similar with their clients? Neither we, nor my friend, had submitted a change of address form & had been doing business at the same addresses for over 10 years.