IRS Tax Controversy

Facing the IRS feels extremely difficult and scary when you do not understand why and what the IRS is after. The IRS uses technical jargon that the average taxpayer does not understand. On top of that, it is difficult to manage the stress when the stakes are high, such as losing your home, facing the threat of criminal prosecution, or closing of your business. Although these are worst case scenarios and they do sometimes come to pass, they are generally not likely outcomes for most taxpayers.  My goal is to zealously advocate for my clients, and I aim to help clients understand the IRS’s process to help allay fears and set reasonable expectations for a path to get beyond their IRS troubles.  For all cases, there is a path to resolving your IRS troubles.

Areas of IRS Tax Controversy

IRS Examination – I can use my accounting and tax law knowledge to represent you and your business in an IRS examination.

Unfiled Tax Returns  – If you have unfiled returns, I can help you prepare back tax returns and work with the IRS to reach a collection alternative if you are unable to pay the tax, interest, and penalties from filing the past due returns. And, I can also help you determine if you should use the voluntary disclosure process to minimize potential criminal exposure.

Offer in Compromise (“OIC”) – Doubt as to Collectibility  – OIC allows taxpayers that are attempting and willing to comply with their current and future federal tax obligations but do not have the ability to pay out outstanding debts to the IRS.
Installment agreement – Installment agreements allow taxpayers a means of repaying the IRS over time and generally prevents more aggressive collection action.
Innocent spouse issues – Signing a joint tax return leads to joint tax liability, but there are some forms of relief from joint liability when your spouse fails to report and meet their income tax obligations.
Injured spouse claims – Sometime the IRS intercepts your refund and applies it to your spouse’s unpaid tax obligation even though you are liable for the debt. In certain cases, you can seek return of the funds from the IRS.
Preventing or removing tax liens – If you owe the IRS a significant amount of money, the IRS may file a federal tax lien, which can lead to issues with obtaining financing. I may be able to help prevent the filing of the lien or have the IRS remove the lien.
IRS levies – The IRS uses the threat of levy to grab your attention. Do not delay in acting. I can usually obtain a temporary hold on a threatened levy action and help you work with the IRS to work out a collection alternative to prevent future levies.
Collection Due Process (CDP) hearings – Certain IRS notices provide CDP hearing rights which provide an opportunity to challenge the IRS’s proposed collection action and sometimes they afford the taxpayer the right to challenge the underlying tax. I can help you assert these hearing rights.
Administrative appeals – If you disagree with the results of your IRS exam, I can help you challenge the IRS’s findings through administrative appeals. This is generally a cost effective choice rather than going to Tax Court.
Offer in Compromise (“OIC”) – Doubt as to Liability – Using as OIC – Doubt as to Liability is a means of challenging the merits of a IRS tax debt even if you no longer have rights to IRS Appeals or Tax Court. I can help you prepare the offer and advocate for a favorable settlement of your liability.
Audit Reconsideration – Even if you missed the deadlines to challenge the results of your IRS examination in Appeals and Tax Court, I can help you use an audit reconsideration as a way of attempting to reduce your federal tax liability.
Trust fund recovery penalty – The IRS may attempt to personally assess “responsible” parties for a business’s failure to pay certain payroll taxes. I can help you fight the assessment and attempt to minimize any personal liability.

If you need help, let’s talk. No cost or obligation for the first discussion.