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Tax Resolution

We understand the overwhelming fear and anxiety that is often associated with tax issues, often coupled with the frustration of not finding clear answers. Our professionals will give your case the care and attention it deserves by laying out all of your options, making sure you are advised of your rights, and advocating on your behalf. Never let tax issues linger. Even a small tax liability can become a major problem if it is left unresolved. We are here to assist you with any tax issue you are facing, including the following.


Audits

Facing an IRS audit is a terrifying experience for most taxpayers.  Knowing that an IRS agent plans to thoroughly review your records and put you on the spot with difficult questions can be overwhelming.  We have represented both individuals and businesses in IRS audits, fighting to protect our clients’ rights and ensuring that all information has been considered.  Don’t risk taking on the IRS yourself.  Contact us to speak with an attorney to know your rights in an audit and how we can help.


Audit Reconsideration

If you are unsuccessful in challenging the IRS in an audit, there is still a chance to resolve the issue before taking the case to court through an audit reconsideration. This process allows a taxpayer to re-submit their position challenging an IRS audit decision by providing all relevant evidence, facts, and law, which is reviewed by the IRS.


Challenging Taxes in Court

Sometimes tax issues are forced to be resolved in court.  This typically occurs when all administrative appeals with the IRS have been exhausted.  It is critical to have the assistance of an experienced tax attorney when challenging the IRS or state taxing authority in court as it requires a deep understanding of tax law and strict procedural requirements.


Complex Tax Preparation

The U.S. tax code is a massive body of complex laws and regulations intended to shape economic and social policy.  The average American is overwhelmed by this complexity, especially self-employed individuals.  Our professionals, including our own in-house CPAs, understand this complexity and understand how to accurately prepare tax returns, ensuring that the letter of the law is being carried out while also looking ahead for future tax savings.


Criminal Tax Issues

Criminal tax investigations  and ultimately indictments are very serious matters that require the immediate need for an attorney.  If the government believes you have intentionally failed to file your tax returns, underreported your income, overstated your expenses, or otherwise evaded the payment of tax, you could face serious criminal penalties including jail time.  Contact an attorney for a free consultation to discuss your legal options.


Discharging Taxes in Bankruptcy

There’s an old saying that all roads in law end in tax or bankruptcy.  Our bankruptcy courts provide an opportunity for insolvent and financially struggling taxpayers, including individuals and businesses, to get a fresh start with their tax liabilities.  Our firm focuses solely on the tax aspects of bankruptcy and can often re-litigate tax issues in bankruptcy court.  If you are considering bankruptcy, please contact an attorney.


Employment/Payroll Tax

The IRS is authorized to hold individual taxpayers liable for the employment/payroll taxes owed by a separate business when certain conditions are met, often referred to as “trust fund penalties“.  This is an extremely powerful tool for the IRS as it essentially “pierces the veil” of liability protection provided by LLCs and corporations and allows the IRS to hold individuals responsible, including employees with no ownership interest in the entity.  The IRS conducts an initial report to determine if a taxpayer is responsible for these trust fund penalties.  It is critical to be advised of your rights and consult a tax attorney.


Innocent Spouse Claims

One of the most commonly rejected claims by the IRS is innocent spouse relief.  This relief allows a taxpayer to escape liability when their spouse incurred understated income or overstated expenses, the taxpayer had no knowledge of the under or over reporting and it would be unfair to hold the taxpayer liable.  These are extremely high hurdles to overcome and the skill and experience of a tax attorney can quickly narrow down your options.  In addition to innocent spouse relief, the IRS provides other equitable remedies for spouses who are not directly responsible for a joint tax liability.


Levies, Liens & Garnishments

Leviesliens, and garnishments are some of the most powerful tools used by the IRS and state taxing authorities to collect taxes.  Levies are legal instruments issued by the IRS to third parties, requiring them to turn over money owed or belonging to the taxpayer to the IRS.  For self-employed individuals and businesses, the IRS can issue levies to vendors and contractors, requiring them to pay money owed to you to the IRS instead.  The IRS can also levy taxpayers’ bank accounts, which can be devastating.  Garnishments are similar to levies, except they require employers to withhold the wages of a taxpayer with a tax liability.  Finally, liens are legal instruments filed with local governments that encumber all taxpayer property, including real estate and personal property.

If you are facing levies, liens, or garnishments, it is critical to contact a tax attorney to ensure your rights are represented and to stop these measures.


State Sales Tax Issues

One of the greatest challenges facing businesses is the ever-increasing use of sales, use, and specialty taxes by state governments to collect revenue.  These taxes are often confusing and hard to track without proper accounting systems in place.  This usually results in additional tax assessments through audits where estimated figures can be used if records and accounting information were not properly kept or recorded.  These results can be devastating, leading to massive tax liabilities, including interest and penalties.  If the audit assessment is bad enough, a criminal investigation may be recommended.  It is critical that you consult with an attorney if your business is facing a state sales tax audit.


Taxation of International Income

The U.S. is one of the few countries that taxes its citizens on all income, even income earned overseas.  The U.S. also taxes nonresident and resident aliens who earn U.S.-sourced income.  In addition to these income tax reporting requirements, the U.S. government requires taxpayers to file information returns to disclose offshore assets such as bank accounts and real estate.  These requirements often cause reporting and compliance issues.

Failure to disclose these assets and report any taxable income generated from them can result in serious civil and even criminal penalties.  To enforce these laws, the U.S. government requires foreign banks to disclose the names of its citizens who maintain foreign accounts.  Luckily, taxpayers can attain compliance by entering into a voluntary disclosure program where amended tax and information returns are filed along with a penalty.  For more information on these voluntary disclosures, please see our Offshore Assets page.


Tax Settlements/Offer in Compromise

You have probably heard one of those “1-800” tax resolution companies promise “pennies on the dollar” tax settlements with the IRS.  This is a legitimate program authorized by I.R.C. § 7122 and commonly referred to as an Offer in Compromise.  These settlement opportunities are typically based on a taxpayer’s inability to fully pay the tax liability owed.  The taxpayer’s income, expenses, assets, and liabilities are calculated using an IRS-defined formula, which determines whether a taxpayer qualifies for a settlement.  The IRS generally accepts less than 50% of all submitted offers.  This emphasizes the need to consult an experienced tax attorney.  We have saved taxpayers millions of dollars through tax settlements and stand ready to help you.


Tax Whistleblower Claims

The IRS will provide money to individuals who report taxpayers who fail to pay their taxes or intentionally underreport income or overreport expenses.  The law provides for two types of awards: (1) if the tax in dispute exceed $2 million, and a few other qualifications are met, the IRS will pay 15 percent to 30 percent of the amount collected; and (2) if the $2 million threshold is not met, the maximum award is 15 percent.  The advice and experience of a tax attorney is often the difference between a successful claim and an unsuccessful claim.

Common Tax Issues

+ Audits
+ Audit Reconsideration
+ Challenging Taxes in Court
+ Complex Tax Preparation
+ Criminal Tax Issues
+ Discharging Taxes in Bankruptcy
+ Employment/Payroll Tax
+ Innocent Spouse Claims
+ Levies, Liens & Garnishments
+ State Sales Tax Issues
+ Taxation of International Income
+ Tax Settlements
+ Offer in Compromise
+ Tax Whistleblower Claims

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