Meet Marc Dombrowski, EA

You'll want to get to know who's presenting your event on December 10. Meet Marc!

Marc J. Dombrowski, EA Tax Help Associates Inc PO BOX 889, Hamburg, NY 14075
716.634.6200   716.634.9570-Fax. Cell- 716.777.1882 [email protected]

He has two successful YouTube Channels (True Resolve Tax Professionals). Owner of Tax Help Associates, Inc., True Resolve Tax Professionals, Hamburg Payroll LLC, and Hamburg Tax Services, Inc. 

Marc J. Dombrowski, EA, specializes in IRS/State Collections Cases, settlements with the IRS, Tax Lien Releases, and Corporate Officer Assessments.  He has lectured since 1994 on advanced collection topics. As an Enrolled Agent, he is licensed to practice before the IRS in all 50 states. He received the NAEA President’s Award for his contributions to the practitioner community.

As an educator, he received the NAEA’s Excellence in Education Award. He is a former contributor to CNBC, Tax Talk Today, the NAEA's EA Journal, and the Wall Street Journal Online. He is a Level I, Level II, Level III, and Graduate Level instructor with the National Tax Practice Institute. In addition to several Chapter EA speaking engagements, he has spoken for Latino Tax Fest, California SUPERS, the NYS Society of EA's, CA Society of EA’s, Florida EA Society, Missouri Society, NJ Society, Tennessee, Washington, Arizona, Michigan, Georgia, Louisiana, New England EA’s, Utah EA Society, NATP and the Ohio EA Society's Annual Convention(s).  He has collaborated with Tax Practice Pro to provide several Collections Webinars and Podcasts that qualify for Continuing Education on IRS and State Collection Topics. Marc is also a FINRA Arbitrator. 

Through his extensive national experience solving a variety of business & personal tax and debt problems, Marc has gained experience in resolutions to fit any situation. “There is no problem, big or small, that cannot be resolved; there is always a light at the end of the tunnel, just take the time to talk to me about it.”

IRS Trust Notice Errors Round 2 - Levy notices

f your client’s trust received an incorrect underpayment of estimates notice in the spring, they will most likely be sending you an intent to levy notice now.

From the AICPA – they are recommending calling and requesting a hold and suggests filing a Form 9423. They are also waiting for an official response from IRS on how to handle the matter.

Current IRS systemic issues

There are several current IRS system issues we have heard about from members. We have notified IRS about:

1. IRS CP504B erroneous intent to levy and CP161 erroneous notices to trusts on Form 1041, individuals on Form 1040 and corporations on Form 1120 on correctly paid estimated payments based on 100% of prior year liability.
   
   After the AICPA identified and communicated to the IRS prior to May 2, 2025, that the IRS was sending erroneous CP161 notices on Forms 1041, 1040 and 1120 estimated payments penalties when the taxpayer paid 100% of prior year liability, the IRS investigated the situation. The IRS’s IT group is aware and, as of Aug. 14, 2025, updated its systems coding with a program fix that was deployed in mid-July 2025 to prevent this issue for returns processed after mid-July 2025 to prevent in the future such erroneous notices on estimated payments when 100% of prior year liability is paid.

On July 29, 2025, the AICPA notified IRS that these same taxpayers are now receiving CP504B erroneous notices of intent to levy. Our IRS contact has elevated the issue within IRS, and the IRS is planning an external communication on it soon, and suggests in the interim, any accounts that receive a CP504B erroneous notice of intent to levy should call and request a hold on collection until we hear more from IRS on this situation.

A practitioner expert on IRS collections issues advises that practitioners with clients receiving a Notice CP504B, Notice of intent to seize (levy) your property or rights to property, from the IRS should file Form 9423, Collection Appeal Request, by certified mail within 30 days of the date on the Notice CP504B. Notice CP504B is usually the fourth notice in the notice stream. Notice CP504B threatens IRS levy and lien action and gives taxpayers rights to protest the filing of a federal tax lien before the federal tax lien is filed and before a levy is issued. Filing a Form 9423 is the only right the taxpayer has to go to the IRS Independent Office of Appeals (Appeals) before a federal tax lien is filed. Calling the IRS and receiving a collection hold on the account for 30-120 days does not stop or hold the running of the 30-day period to file the Form 9423. If the Form 9423 is not filed within 30 days from the date on Notice CP504B, the taxpayer loses the right to go to Appeals before the federal tax lien is filed and before a levy is issued. Once the case is resolved, and if the appeal is not heard, Form 9423 can be withdrawn. For further information on Form 9423, read the instructions on the back of Form 9423 and Internal Revenue Manual (IRM) 5.1.9.4, Collection Appeals Program (CAP).

In addition, regarding the CP161 notices, it has been suggested to request that IRS Practitioner Priority Service (PPS) phone assistors manually adjust accounts, and/or a collection hold be placed on any accounts that have received an erroneous CP504B intent to levy notice.

When calling the IRS to assist with this incorrect CP161 notice issue, we suggest referencing a May 2, 2025, “SERP Alert 25A0128,” an IRS internal update that was sent to IRS telephone assistors regarding incorrect CP161 notices for failure to pay proper estimated tax. The alert indicates that the estimated tax penalty was systemically incorrectly computed without regard to prior year estimated tax base, and the penalty should be reduced or removed. It may be helpful if you are able to speak with a “Service Center” assistor who may have more access to abate the penalty. We are hopeful that the IRS will provide an external communication on this issue soon. The AICPA will continue to monitor the situation and be in touch with our IRS contact.