It never ceases to amaze me when I hear a story of IRS abuse. You substantially won, but IRS has you targeted and come back every few years (to avoid the problems that arise when they come back the next year after losing - it's abuse, and relief is granted by the courts).

Since your prior year arrears are classified as uncollectible (53), even if IRS did pursue you for something, it's not likely they can actually get paid.

I have an idea for you. As you know, representing yourself before IRS is a full time job, and stressful in a way most can't understand. Hiring a tax pro, which you have done, is costly and might be unnecessary. Once you have been calling the Revenue Officer and the Taxpayer Advocate so much they won't return your calls, it's time for the big guns.

1. I would make a FOIA request for their entire file, and let the Revenue Officer and Taxpayer Advocate know you have made the request. Send them copies of the letter. In it, you should ask for the complete IRS file, including everything you can locate about your prior tax cases, your DIF score, their litigation file, everything. Ask a tax pro to help, since your request is a legal one, and a poorly drafted FOIA request will not get you what you want. They charge for photocopying, so plan on spending some $ for all the paperwork.

2. Since this request is often made by taxpayers considering tax litigation, you will get everyone's attention. I would then ask for a collection and audit stay until the documents have been processed and delivered, and add a month or so to review them. You should make that request of the Advocate. You do not need to reveal your intentions to make this request, only that these documents are on their way.

3. You have strategy options here. Since a Revenue Officer has been involved, I assume an audit or other adjustment has been proposed. You might consider just taking your case to Appeals, or an audit reconsideration if available, where a fresh IRS representative will look at your case (removes RO and TA) and might close or otherwise settle the case.

4. If Appeals has failed, submit an Offer in Compromise, using the grounds of effective tax administration. Your FOIA request will be invaluable here, since you will be able to use IRS documents to prove they should drop this and move on to other taxpayers.

5. You didn't go into your uncollectible status very much, but there is an additional forum I would consider: bankruptcy court. Bankruptcy courts do have a little-used power to reset liabilities which supersedes IRS audit/appeals. Consult a bankruptcy pro to advise.

6. Yes, it looks like you can litigate for damages. The FOIA documents and your own story will be compelling evidence. The fact that you have been in court with IRS (did you make a deal, or litigate to a decision?) would normally scare them off. Having them come after you, knowing you are uncollectible, might be demonstrable to a judge that abuse of authority has occurred.

7. I know I mentioned it before, but please consider hiring a tax pro to represent you. These issues are too much and too important to blow the statute by missing a filing deadline, for example.

Keep in mind your state (NY) will require reporting of any changes to your filed returns as well. Their interests must be considered and settled as well.

Just a few thoughts. Thanks for asking from Just Answer, ask more if you need to. Add positive feedback if I gave you something to work with.