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Practice Areas

IRS Audits & Examinations

An IRS audit and an examination are the same thing. The IRS refers to an investigation into the numbers in a tax return as an examination. These examinations audit the records a taxpayer presents in support of his or her tax return. What to Do Before… Read More

IRS Liens, Levies & Seizures

An IRS tax lien is simply the formal recording of a tax liability that arises automatically upon formal assessment of the tax. It is filed by the IRS in the county where the taxpayer resides. It becomes an encumbrance on all of the property then owne… Read More

IRS Installment Agreements & Offers in Compromise

When taxpayers have fallen behind on their obligations to the IRS, securing an installment agreement can provide a structured path to coming back into compliance. Securing an installment agreement is very similar to the process for securing an offer… Read More

Restoring Non-Filers to IRS Compliance

For many people who stop filing tax returns with the IRS, it is all too easy for one year of not filing to turn into multiple years. The IRS refers to people in that position as nonfilers. The IRS view nonfilers as a major challenge for the organizat… Read More

Relief from Joint & Several Liability (“Innocent” Spouse Relief)

Both spouses on a married filing jointly return are generally held responsible for all the tax due even if one spouse earned all or a much larger proportion of the income or claimed all the improper deductions or credits. In appropriate cases, howeve… Read More

Trust Fund Recovery Penalty

The Internal Revenue Code requires persons other than taxpayers to function as withholding agents for collecting certain taxes for the IRS. Section 6672 of the Internal Revenue Code provides that any person who is required to collect, truthfully acco… Read More

Abatement of Civil Penalties

If your tax payments are past due, penalties will be assessed and interest will continuously accrue. Because penalties and interest are seen as part of your overall tax liability, it is extremely difficult to get the Internal Revenue Service (IRS) to… Read More

IRS Administrative Appeals

Within the IRS system, the Appeals Division is intended to have final authority to determine tax liability, to function independently of the units whose determinations are being appealed, and to act “with strict impartiality between the taxpaye… Read More

U.S. Tax Court Petitions

The United States Tax Court is a court of record established by Congress under Article I of the U.S. Constitution. When the Commissioner of Internal Revenue has determined a tax deficiency, the taxpayer may dispute the deficiency in the Tax Court bef… Read More

Refund Litigation Against IRS in Federal Courts

The Internal Revenue Code contains two different methods by which taxpayers can bring their substantive tax controversies to litigation: (1) deficiency procedures and (2) refund procedures. Deficiency procedures relate exclusively to income, estate,… Read More

Private Letter Rulings

Despite the vast accumulation of published Regulations interpreting the Internal Revenue Code, there are inevitably numerous “gray areas” on which no amount of legal research can shed sufficient light to enable a tax lawyer to offer a … Read More

IRS Audit Reconsideration

The Internal Revenue Code allows the IRS to abate any assessment of tax and applicable interest and/or penalties if the assessment is excessive, erroneously or illegally made, or made after the statute of limitation has expired. To implement this pri… Read More

FBAR, FATCA and Offshore Voluntary Disclosure Initiatives

The Bank Secrecy Act of 1970 and subsequent legislation require individuals who hold assets in overseas financial institutions of $10,000 in aggregate value to report these assets to the IRS. Failure to comply with the Foreign Bank Account Reporting… Read More

Foreign Bank Account Reporting (FBAR) Requirements

The Foreign Bank Account Reporting (FBAR) requirements were enacted in an effort to combat tax evasion and spur compliance with U.S. tax laws. After years of low compliance, Congress amended the FBAR legislation in 2004 with more stringent rules, enh… Read More

Offshore Voluntary Disclosure Programs (OVDP)

To encourage taxpayers with offshore bank accounts and assets to come forward and comply with Foreign Bank Account Reporting (FBAR) requirements – including those enacted by the Foreign Account Tax Compliance Act (FATCA) – the federal government… Read More

The Foreign Account Tax Compliance Act (FATCA)

The Foreign Account Tax Compliance Act is the latest in a series of laws and regulations designed to combat tax evasion by U.S. persons holding financial assets offshore. As applicable to individual taxpayers, FATCA requires that certain U.S. taxpaye… Read More

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