Don't Fight the IRS Alone!
We are a tax controversy law firm with an experienced and skilled team of Tax Attorneys, CPAs, and IRS Enrolled Agents. We know how to get results with the IRS and we are ready to help.
Federal (IRS) Tax Issues
We are a law firm that represents individuals and businesses facing tax issues with the Internal Revenue Service (IRS). Our team of tax professionals understands the overwhelming fear and anxiety often associated with IRS tax issues. We also understand that achieving a favorable outcome with the IRS requires expertise in tax law and an understanding of the IRS's procedures and policies. Our team of experienced attorneys and tax professionals uses our knowledge, training, and experience to provide clear guidance, honest legal counsel, and peace of mind in difficult circumstances.
We invite you to browse the topics below or request a consultation with a tax attorney to learn more about how a tax attorney can help you.
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How We Can Help
Assisting clients in resolving outstanding tax debts with the IRS, such as negotiating installment agreements, offers in compromise, or currently not collectible status with the IRS.
Representing clients during IRS audits, ensuring compliance, and advocating for the client's interests throughout the audit process.
Tax Appeals
Representing clients in appealing IRS decisions or tax assessments to the Office of Appeals, ensuring proper application of tax laws and regulations.
Assisting clients who are facing tax liability due to a spouse or former spouse's erroneous or fraudulent tax reporting.
Assistance with unfiled personal and business federal income tax returns.
Tax Penalty Relief
Helping clients reduce or eliminate tax penalties imposed by the IRS due to late filing, late payment, or other infractions.
Representation for Tax Return Preparers Facing IRS Investigation, Suspension/Expulsion from IRS E-file, and return preparer penalties.
Assisting clients in disclosing offshore accounts and assets to the IRS under voluntary disclosure programs to avoid severe penalties and potential criminal charges.
Tax Liens and Levies
Providing guidance and representation to clients dealing with IRS tax liens or levies on their property or assets.
Case Results
We are committed to delivering results and invite you to review a sample of representative matters we have resolved for our clients. All cases are different and the summaries below should not be interpreted as a prediction or guarantee of success or specific results.
IRS Crypto Penalty Abatement: $523,825.26 Eliminated
The ProblemOur client was assessed over $1 million by the IRS for alleged unreported cryptocurrency transactions. The assessment included substantial accuracy-related penalties under IRC §6662(a) and arrived with one of the most serious enforcement notices the IRS can issue: a Notice of Intent to Levy. At that point, the IRS had the legal authority to begin seizing assets. The taxpayer maintained that the reporting errors were not intentional and stemmed…
IRS Tax Preparer Fraud Investigation Closed With No Findings Under IRC § 6700, 6701, 6694, and 6695
DeWitt Law represented a high-volume federal income tax return preparer after the IRS opened an investigation involving potential civil penalty allegations under IRC §§ 6700 and 6701, as well as potential IRC § 6694 and 6695 return preparer violations. Immediately after being notified of the investigation, the client retained DeWitt Law to provide legal representation and early intervention. Our firm took over the matter from the outset, handled all communications…
DeWitt Law Secures Full Reversal of $250,000+ IRS Assessment
Taxpayer recently received an IRS CP2000 notice proposing additional tax of more than $250,000 related to the sale of the Taxpayer’s primary residence. The notice alleged substantial unreported income and sought to impose a staggering assessment. DeWitt Law immediately identified critical errors in the IRS’s proposed assessment. Our team carefully reconstructed the transaction details, highlighted the primary residence exclusion under federal tax law, and documented the accurate basis and closing…
$300,000 Payroll Tax Debt Placed in Currently Not Collectable (CNC) Status by the IRS
After a prolonged cash‑flow crunch, a car repair shop fell behind on payroll tax deposits. The owner was also personally assessed under the Trust Fund Recovery Penalty (IRC Section 6672), resulting in approximately $300,000 of federal payroll tax debt. After receiving Notices of Intent to Levy from the IRS, the Taxpayer contacted DeWitt Law. We moved quickly to protect the client: we filed a timely Collection Due Process (CDP) request…
Streamlined Disclosure For Unreported Foreign Income & Bank Accounts
A U.S. taxpayer engaged DeWitt Law after discovering his prior CPA never told him about FBAR and U.S. foreign-income and tax reporting. The Taxpayer was worried, confused, and facing the risk of steep penalties. DeWitt Law quickly jumped in, mapped out a clear path using the IRS’s streamlined disclosure process, and handled everything—from organizing foreign account records to preparing the right filings—to get the Taxpayer into full compliance. Our team…
Reversal of Expulsion From IRS E-File Program
Tax Return Preparer received a letter from the IRS expelling their firm from electronically filing tax returns through the IRS e-file program. Tax Return Preparer received the expulsion notice after the 30-day window to appeal the expulsion. DeWitt Law represented Tax Return Preparer before the IRS to challenge the expulsion. After filing a claim with the IRS TAS Service, the IRS Office of Appeals allowed an administrative appeal to proceed….
$141,854.73 Recovered From IRS in Claim for Refund Case
Taxpayer owed federal income taxes for tax years 2019 and 2020. Taxpayer was not able to fully pay their tax debt when it was due, causing accrual of substantial failure-to-pay penalties. Taxpayer eventually fully paid the tax debt but sought to recover a refund of the penalties paid. DeWitt Law represented Taxpayer before the IRS. DeWitt Law filed a claim for refund with the IRS, arguing that Taxpayer qualified for…
$138,605 Federal Income Tax Debt Settled For $33,085
Taxpayer, who was self-employed, owed $138,605 in federal income tax debt to the IRS for multiple tax years. DeWitt Law determined that the Taxpayer could not fully pay the tax debt within the time remaining under the statute of limitations for IRS collections. DeWitt Law represented the Taxpayer before the IRS and submitted an Offer in Compromise proposing to settle the tax debt. The IRS erroneously rejected the Offer in…
$507,443.65 Tax Liability Reduced to $13,391.08
Taxpayer owed $507,443.65 in federal income tax debt to the IRS for multiple tax years. The IRS issued a Notice of Intent to Levy, threatening to garnish the Taxpayer’s wages and levy their bank accounts. DeWitt Law represented the Taxpayer before the IRS and filed a Collection Due Process request to resolve the tax debt and prevent further IRS collection action. The IRS Office of Appeals held a Collection Due…
$291,791.44 Tax Liability Reversed to $0
Memphis, TN – Taxpayer received IRS Notice CP2000 proposing additional tax of $181,404 for tax year 2018. Taxpayer’s accountant assisted with responding but the IRS upheld the assessment and issued a Notice of Deficiency. Taxpayer did not challenge the Notice of Deficiency and the assessment became final, resulting in a total tax liability, including penalties and interest, of $291.791.44. The IRS applied held Taxpayer’s tax refunds for later years and…
Proposed Federal Income Tax Liability Reduced to $0
Tampa, Florida – Taxpayer received IRS Notice CP2000 proposing additional federal income tax for tax year 2022. The basis for the proposed assessment was self-employment income reported by DoorDash that was never earned by the Taxpayer. DeWitt Law represented the Taxpayer before the IRS and challenged the proposed assessment. The IRS reversed the assessment in full to $0.
$74,177 Federal Income Tax Assessment Reversed to $0
Birmingham, AL – Taxpayer received IRS Notice CP2000 proposing additional federal income tax for an unreported taxable retirement distribution. DeWitt Law represented Taxpayer and challenged the proposed assessment, arguing that the Taxpayer qualified for an automatic waiver of the 60-day rollover requirement established under I.R.C. § 408(d)(3). The IRS reversed the proposed assessment.
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Tyler H. DeWitt, Esq., CPA
Managing Attorney