Our Tax Resolution Practice Group employs a team approach to assist individuals, businesses and their CPA’s and attorneys with the resolution of Federal and State tax controversy matters. Every tax collection and audit matter requires a solution uniquely tailored to the needs of each client. Whether past due taxes to the IRS or State, unfiled tax returns or IRS or State audit, we navigate complex tax issues and provide the best advice and representation for your unique tax situation. Our tax attorneys have decades of IRS experience, both working for the IRS and advocating on behalf of taxpayers in private practice.
We have a proven track record of filing successful Offers in Compromise for clients. At the beginning of each representation we determine if the client qualifies for the Offer in Compromise program and the range of possible outcomes. We then guide the client through each step of the Offer in Compromise process from filing the Offer to negotiating a settlement that can result in significant tax savings. Most our cases settle for a fraction of the client’s original tax liability.
The IRS allows individuals or businesses to pay their Federal tax liabilities over time with a wide variety of installment payment agreement options. We examine each client's unique financial situation and tailor the best installment agreement solution whether through the IRS Fresh Start program, full payment agreements, partial payment agreements or agreements based on the client’s ability to pay.
We regularly advise and assist clients regarding Federal and State tax liens and levies. Our tax attorneys help clients resolve wage garnishments, bank levies, retirement account levies and Social Security levies. We also help clients resolve State license and registration blocks. We regularly assist clients who are selling property in obtaining tax liens discharges and counsel clients on the effect of Federal and State tax liens on their credit and how to avoid lien filings.
Our tax resolution practice uses a comprehensive approach when representing a client with unfiled tax returns. We assist the client and their CPA or tax preparer with filing the late tax returns. In addition, we work with IRS or state tax authorities to correct any estimated or substitute tax returns. Throughout this process, we proactively work with the client to develop and implement an all-inclusive plan for resolving any tax liabilities once the tax returns have been filed.
We represent clients and consult with accountants regarding Federal and State tax audits, including personal and corporate income tax, employment and State sales tax audits. Drawing on years of IRS experience and knowledge, we develop a strategic response to each audit to achieve the best results for the client. Whether we are representing a business or individual, we work directly on the audit or behind the scenes with the client’s accountant to navigate complex audit issues and bring the audit to a quick and efficient resolution.
We represent clients through all types and stages of IRS appeals including Collection Due Process hearings, audit reconsiderations and trust fund recovery determinations. We utilize our in-depth and firsthand knowledge of the IRS Appeals process to successfully resolve our client's tax collection and audit cases. Our tax attorneys are also admitted to practice in the U.S. Tax Court where we frequently represent clients in challenging IRS cases.
The IRS offers relief from joint tax liabilities in certain circumstances. Our tax resolution attorneys are experienced in preparing and filing successful innocent spouse relief requests with the IRS. We understand the sensitive issues that arise in these matters and take the time to fully explain each client’s unique circumstances to the IRS.
We use penalty abatement as one of two tools to reduce a client’s Federal and State tax liabilities. Whether utilizing first time abatement programs or asserting reasonable cause, our tax attorneys work with clients, the IRS and State tax authorities to abate or reduce penalties during all phases of audit, appeals and collections.
We understand that sometimes clients cannot afford to pay their outstanding tax liabilities. We advocate hardship status on behalf of clients to allow them time to resolve their financial issues without the threat of enforced collection activities from the IRS or local officers and examiners. We address future tax compliance and help formulate a plan for resolution of the tax liability once the client's financial condition improves.
Foreign account reporting and compliance is one of the least understood areas of tax law affecting ordinary taxpayers. Innocent and inadvertent missteps can result in reporting failures that permit the IRS to exact substantial penalties on foreign accounts. We regularly work with clients who invest outside of the United States and require assistance with both outbound transfers and repatriation of profits as well as clients who have inherited a foreign account.