Tax Crisis Representation
Civil Liability, Criminal Risks and Defense, Administrative Appeals, and Court Representation.
IF IT’S ABOUT TAX, WE UNDERSTAND.
But unlike others, we don’t just rely on some calculated “formula.” Imposing a “formula” on your facts – on your life – does not reach the best results available.
Don’t let someone with a calculator shape your future. Talk to us. You’ll see. You’ll also come to understand.
It does not matter where you are in the United States, or for that matter, the WORLD. We can help you.
The reality is, the final RESULT in any dispute is dramatically – compelling influenced by our ADVOCACY.
We are trained, deeply experienced.
We are advocates.
The resources we bring to these matters not only include, but go far beyond what other attorneys,
accountants, paid return preparers and financial planners and investment analysts can bring.
We have 39+ consecutive SUCCESSFUL YEARS OF CLINICAL EXPERIENCE as advocates for clients in distress.
We have the track record to prove it.
WE HELP ACCOUNTANTS, PREPARERS, C.P.A.s, and FINANCIAL PROFESSIONALS
We know what you need to succeed.
Intense IRS and enforcement agencies review of work product and the methods you use is a reality.
Algorithms automatically scrutinize virtually everything. Resulting licensing, litigation and IRS audits can compromise your entire book of business. Clients are interviewed – if not interrogated – over a period of months and sanctions have expanded to include public reprimands, suspensions, disbarment, heavy financial penalties, potential third party liability to clients and even others. Criminal investigations and charges have also resulted.
It is a gross understatement to characterize evolving review procedures and due diligence standards as being in a state of flux. Whatever the intention, some are created and applied retroactively or arbitrarily implemented in ways that completely ignore your due process rights, the adverse impact on your business relationships and the reality that you have to keep your office functioning. We understand your professional commitment, that this is your livelihood.
We also understand the nature of your challenges and your risks.
Rely on us. We can:
1) Confidentially review your business practices and methods and conform them to & exceed due diligence compliance requirements.
2) Address federal and state enforcement reviews and audits of your work, selected client matters and all challenges to your license privileges.
3) Advise and represent you in civil litigation so you can rely on the full scope of our experience.
4) Represent you in formal civil or criminal investigations, administrative charges, threats, suspicions or risks and in any related court proceedings.
We know how to solve problems.
We also insulate you from direct agency contact.
Call & talk to us.
It doesn’t matter where you are located because we can work electronically, including video conferencing, but of course you’re welcome to come and talk to us.
In fact, you’re invited. We’ll buy lunch.
The sooner the better.
EMPLOYERS – DON’T GET SHUT DOWN
STAY IN BUSINESS
Unless you know the rules and your rights the IRS will threaten that it will shut your business down and make you personally pay the delinquency.
There are alternatives that can prevent that from happening.
One alternative is settlement.
Employment & Business Tax Challenges – The IRS May Want You to Personally Pay!
This is true even if the tax delinquency involves employment taxes or “trust fund” taxes & every type of legal business and profession is eligible.
That means they remain true to their customers and employees and there isn’t any disruption to its relationships with its banks, other creditors or suppliers.
Their good will continues to grow.
YES, BUSINESSES CAN SETTLE DELINQUENT IRS EMPLOYMENT TAX LIABILITIES AND REMAIN IN BUSINESS
We know how to maximize your position.
The IRS (or State) will do that if you are:
1) an Officer or employee of the business, or
2) a Partner, director or shareholder, or
3) a member of a board of trustees of a nonprofit organization, or
4) a person with sufficient authority and control over funds to direct their disbursement.
Accountants, attorneys and financial planners have been determined to be
responsible parties & when the business can’t pay the delinquency, they must.
GET WITH US AS SOON AS YOU SUSPECT YOU MAY BE A TARGET…
AND IMMEDIATELY AFTER YOU ARE CHALLENGED BY THE IRS
There are specific procedures in place to challenge these determinations by the IRS,
but there are specific time frames within which you must act.
So, get with us as soon as things are made know to you.
WHAT IF YOU ALREADY MISSED THOSE DATES?
Procedures may be available for you to address the matter without having to pay the entire liability that’s been attributed to you,
but you have to get with us so we can review your history and see what can be done.
We might be able to have the entire determination set aside without filing suit and without your having to first pay the liability.
That is huge.
WE ARE ADVOCATES
Over the years, we’ve successfully avoided personal attribution for thousands of individuals and have reversed “responsible party” determinations for hundreds
and hundreds of others. In some of those cases we’ve also proved that the IRS’s earlier assessment against the business was incorrect (for example) in tax
periods six, seven and eight years earlier. And when you consider that penalties and interest can add up to hundreds of thousands of dollars, it’s worth looking into.
We represent Accountants, Tax Return Prepares, C.P.A.S, and Financial Advisors. This includes civil liability matters, criminal risks and defense, as well as due diligence and licensing challenges.
Back Taxes Owed
Have you filed your tax returns every year, but not paid all the tax you owe? Maybe you just didn’t have enough money at the time and planned to pay more later. Unfortunately, the penalties and interest that are added to back taxes greatly increase how much you will ultimately owe the government. If you are delinquent on your taxes and haven’t yet heard from the IRS, you soon will. The IRS may place a lien on your property or a levy on your bank accounts or wages. The potential damage from unpaid back taxes can be financially ruinous, but it is often avoidable. We can help you assess your tax debt options and negotiate a workable payment plan with the IRS. Unpaid back taxes is a problem that rarely goes away on its own. Contact us today and resolve your tax liability issues.
A bank levy freezes your bank accounts. Any checks you have written will bounce. You will not be able to withdraw any funds or pay any bills. Generally, you have 21 days to respond to the IRS after your financial institution receives a Notice of Levy for your accounts. After that, your accounts are drained and the money is sent to the IRS. If you act immediately, we may be able to get the levy revoked. Together, we can compile and forward the IRS the information they require to release the levy. We will also negotiate the best possible payment arrangement the law and your finances allow.
Currently Not Collectible/Hardship Status
If paying your tax debt would cause you undue financial hardship, you may qualify for Currently Not Collectible (CNC) status. If the IRS decides your case is legitimate, they will halt collection for the duration of your CNC status, although you may still be subjected to a lien. Generally, to be accepted as Currently Not Collectible you must demonstrate to the IRS that you cannot pay your tax debt after meeting monthly living expenses or by liquidating certain assets. Applying for hardship status on your own is time-consuming and can ultimately end in failure. Our tax professionals are familiar with IRS rules and regulations. If we feel you have a good chance to qualify for hardship status, we will submit the correct paperwork on your behalf and emphasize your suitability to the IRS. Currently Not Collectible is best thought of as a reprieve from collection enforcement that is subject to review. Once your status is confirmed, however, we can recommend options that will bring your tax controversy to a permanent close.
Injured Spouse Relief
You may qualify for Injured Spouse Relief if the IRS uses the refund from your joint return to offset certain past-due debts that are the sole responsibility of your spouse or former spouse, such as taxes, child support, or student loans. Injured Spouse Relief should not be confused with Innocent Spouse Relief. You may be classified as an Injured Spouse if you do not receive your portion of a refund because of your spouse’s debt, whereas Innocent Spouse Relief applies to debt for which you are technically co-responsible, but not liable because of circumstances. Whatever the cause, we can help you rectify an unfair tax liability and get you your money. Our tax experts will closely examine your case to see if you qualify for Injured Spouse Relief and/or any other IRS Relief programs.
Innocent Spouse Relief
Many married taxpayers file a joint tax return because of the benefits this filing status allows. Unfortunately, the opposite is also true. If you filed a joint return with your spouse or former spouse, you may be held liable for the taxes, interest, and penalties–even if it was your spouse who earned the income and/or claimed improper deductions or credits. This is true even if a divorce decree states that your spouse will be responsible for any amounts due on previously filed joint returns. If the IRS is holding you responsible for your spouse’s or former spouse’s fraud or negligence, we can help. Our experienced representatives will quickly determine if you qualify for tax relief and then negotiate with the IRS for the outcome most favorable to you.
There are three types of relief available.
Innocent Spouse Relief By requesting innocent spouse relief, you can be relieved of responsibility for paying tax, interest, and penalties if your spouse did something wrong on your tax return.
Separation of Liability Relief Under this type of relief, you divide the additional tax owed from your joint return, plus penalties and interest, between you and your spouse (or former spouse).
Equitable Relief If you do not qualify for innocent spouse relief or separation of liability, you may still be relieved of responsibility for tax, interest, and penalties through equitable relief.
Don’t be the victim of someone else’s mistakes or dishonesty. Contact us today to see if you qualify for Innocent Spouse Relief or other IRS tax relief programs.
IRS Audit Representation
Have you received a Notice of Audit and Examination Scheduled from the IRS? An IRS audit is a review of an organization’s or individual’s accounts to ensure information is being reported correctly. Ignoring an audit usually means the IRS files your return for you and you end up paying much more. An IRS audit is a serious situation, but with experienced help most tax difficulties can be resolved. You don’t have to face an audit alone. Our associates are qualified to represent you before the examination division of the IRS. Oftentimes we can save taxpayers many times the cost of representation and quickly bring the audit to a close.
Levies and Seizures
Levies and liens are often confused, but they are actually quite different. A lien secures the government’s interest in your property when you don’t pay your tax debt. A levy actually takes the property to pay the tax debt. If you don’t pay or make arrangements to settle your tax liability the IRS can levy, seize and sell any type of personal property that you own or have an interest in. Even your retirement accounts and home are fair game. If you have received a Notice of Intent to Levy please contact us immediately. There is a brief time period where we may be able to appeal the process and negotiate a workable payment plan before the levy even begins. Levies are best understood by examining their primary asset targets.
A federal tax lien arises shortly after the IRS makes an assessment of your tax and sends you a demand for payment. A Notice of Federal Tax Lien lets your creditors know the IRS has a claim against all your property–including property you may purchase in the future. Once the lien arises, the IRS generally will not release it until the taxes, penalties, and fees are paid in full. But there are actions you can take. If you contact us immediately, we may be able to file an appeal with the IRS and have your lien reconsidered. Our tax experts will thoroughly examine your situation to see if you qualify for a payment or penalty reduction. We can find out if the Statute of Limitations has expired or if your finances allow you to file as Currently Not Collectible. Failing these, we will diligently work to set up a payment plan with the IRS and get the lien revoked.
Obtain Your IRS File (Freedom of Information Act)
The Freedom of Information Act, or FOIA, gives any person the right to access their IRS file. Knowing what the IRS has in your file is a great place to start when resolving a tax issue. Furthermore, it is probably as important to find out what the IRS does not know about you as it is to see what they do have in your file. We will make a discreet request for your information from the IRS so as not to draw undue attention to any tax liability. After we acquire your IRS file, we will explain it to you in layman’s terms, as well as recommend a course of action that will set you on the road to ending your tax controversy.
Offer in Compromise
An offer in compromise allows you to settle your tax debt for less than the full amount you owe. It may be a legitimate option if you can’t pay your full tax liability, or if doing so would create a financial hardship. The IRS will generally approve an offer in compromise when the amount offered represents the most it can expect to collect within a reasonable period of time. But the Offer in Compromise program is not for everyone. We will analyze your financial situation to see if you are eligible. If you do not qualify for an offer in compromise, we can recommend other payment options that will resolve your tax debt.
Payroll Taxes Owed
Falling out of compliance with IRS payroll regulations can destroy your business. Not only that, it can ruin your personal finances. Perhaps you’ve gotten behind on payroll taxes through an oversight or a temporary lack of funds. Whatever the reason, it is important to note that the IRS pays particular attention to small businesses that fall behind on their employees’ federal withholdings. If the IRS decides that your business has violated payroll tax rules it may come after your personal bank accounts and assets–even if your business files for bankruptcy protection. If you have received correspondence from the IRS about payroll issues, you need experienced representation now. Let our tax experts help you resolve your payroll tax issues so you can get back to running your business.
One of the worst things about IRS tax controversies are the penalties and interest tacked on to your original bill. There are penalties for late filing, late payment, and negligence, to name but a few–and the interest on unpaid taxes can rapidly increase your total tax liability. If you are struggling with unpaid taxes plus additional penalties and interest, we can help. The IRS may abate certain penalties if there is reasonable cause and the failure was not due to willful neglect. Many taxpayers who have not previously had major issues with the IRS can qualify for a first time penalty waiver. Generally, the IRS does not revoke interest charges, but some established interest suspension provisions do apply–especially where the IRS has made an error. We understand if you are overwhelmed by penalties and interest. They often appear arbitrary and unfair. We will carefully scrutinize your tax situation to see where penalties and/or interest may be waived.
A Seizure is a levy on your property. The IRS can take your car, boat, jewelry, etc.–sometimes even your home–and then auction off your possessions to pay your taxes, interest, and penalties. If the IRS has notified you that they are going to seize your assets, you still have some legal rights concerning your property. Our associates will walk you through all the available options. You may qualify for an Offer in Compromise, Innocent Spouse Relief, or, if you are under severe financial duress, Currently Not Collectable. If the IRS has already taken your property, we can request an Asset Levy Release–it may be possible to get your possessions back. Please contact us today for more information.
Statute of Limitations
The Statute of Limitations dictates the amount of time allocated for certain tax-related actions. For example, the IRS has three years to audit your tax return or send you a refund, but they have ten years to collect after a tax has been assessed. There are some exceptions to the ten year collection rule. Applying for certain payment arrangements will suspend the ten year time frame while those arrangements are pending, but add extra time to the statute of limitations for your case once the suspension period is over. It is important to know when the Statute of Limitations expires, but it is just as important to know what to do with that information. We have the expertise to help you make those decisions. Sometimes, filing for a certain status or payment plan can do more harm than good. Everyone’s tax debt issues are different and it is critical that all factors be considered. Our tax professionals will find out how the Statute of Limitations applies to your circumstances and then advise you as to the best course of action to take.
Tax Representation and Resolution
There are many issues that can arise between taxpayers and the IRS. If you are facing an audit, lien, or wage garnishment your future and reputation are at stake and you should take immediate action. But going it alone can be a time-consuming nightmare and sometimes result in a worse outcome. Our associates are uniquely qualified to resolve your tax problems and represent your best interests before the IRS and other tax authorities.
If you have neglected to file a tax return from a previous year or years you should do so immediately–even if you think you can’t pay. The penalties and interest you may face for not filing a return are often much worse than if you file but do not pay in full. In other words, you have nothing to gain by not filing tax returns except hefty fines and possible jail time. We have the expertise you need to straighten out your misunderstanding with the IRS.
Once we have filed your missing returns, we can help you work out a payment plan or an Offer in Compromise. Please note that the IRS will not accept any payment arrangement or revoke a lien or levy until all delinquent tax returns are filed. Contact us today to learn more about filing your overdue tax returns.
Wage Levy (Wage Garnishment)
A Wage Levy occurs when the IRS sends a Notice of Levy to your employer demanding that he or she send a portion of your paycheck to the IRS. If your employer fails to comply, they could be held responsible for your tax debt. A wage levy is extremely unpleasant. The IRS usually gets the bulk of your paycheck until your taxes are paid off and your relationship with your employer is put under a great deal of stress. If your wages are being garnished, you need help now. Our tax experts will work with you to arrange a payment plan with the IRS that is far more tolerable than having your regular paycheck docked.