Tax Problem Resolution


For the past 30+ years, I have devoted my legal practice to defending the rights of taxpayers. I have successfully assisted thousands of individuals and small businesses to solve their tax problems. I know what your legal rights are, I am committed to defending your rights in all dealings with IRS and I insist that IRS respect your rights.

These are just a few of the legal options available to solve your tax problems:


The Offer in Compromise (“OIC”) gives you an opportunity to pay a portion of the taxes you owe as full and final settlement of your entire federal tax liability. In May 2012, IRS adopted sweeping changes in the OIC program. As a result of the IRS changes, the up-front payment to IRS for most taxpayers is substantially reduced and the percentage of Offers in Compromise accepted by IRS has risen from 22% to 40%.


Installment Agreements are payment plans in which you are allowed to pay your IRS debt in manageable installments. I have negotiated thousands of IRS Installment Agreements. I can help you come up with an IRS Installment Agreement that is fair and manageable, AND acceptable to the IRS!


I have represented hundreds of small business and individual taxpayers in IRS Audits. I know how the audit process works. I know what documents are necessary to support questioned deductions, and I know from experience how to present your information to insure the best chance of success in the audit. Don’t let an inexperienced accountant or return preparer who has no knowledge of your rights or how the audit process works represent you in a tax audit. There’s too much at stake. You should hire an experienced tax professional to assist you.


When the IRS Auditor issues a “Final Audit Report” it usually shows that all judgment calls were made in favor of the IRS. Auditors will assess the maximum amount of tax, penalty and interest possible (within reason) and move on to the next audit. But the Auditor’s Final Report is not final. The Auditor’s Final Report merely recommends additions to the tax plus penalties and interest. Once the Auditor has submitted the Final Report, you have an absolute right to appeal the IRS Auditor’s findings with the IRS’s independent Office of Appeals. IRS Appeals’ mission is to help taxpayers resolve tax disagreements. Unlike the Auditor, IRS Appeals will typically resolve many issues in favor of the taxpayer. Most of the taxpayers I have represented in IRS Appeals have significantly reduced their tax liability on appeal.


Before IRS can take any money from a taxpayer by garnishing wages or levying bank accounts, IRS is required by law to mail the taxpayer a Letter 1058: FINAL NOTICE OF INTENT TO LEVY AND NOTICE OF YOUR RIGHT TO A HEARING. Before IRS garnishes your wages or takes money out of your bank account, you have an absolute legal right to file a Collection Due Process Appeal and stop the collection action. But you must act quickly. You must file your Collection Due Process Appeal within 30 days of the date of the 1058 letter. In most of the collection due process appeals I have filed, the IRS has accepted an installment agreement or some other reasonable collection alternative the taxpayer can afford. The Collection Due Process Appeal is a powerful tool the law provides to assist taxpayers in getting a fair shake. If you received a Final Notice of Intent to Levy and Notice of Your Right to a Hearing, you must act now! Don’t let the appeal time expire.


Even if you’ve already received a Letter 1058 and you failed to file a timely Collection Due Process Appeal, you still have many other valuable collection defense rights. As I said before, there is no such thing as a hopeless tax problem!


Innocent Spouse Requests are one of my specialties. I have filed many of them successfully. I have even taught seminars to other lawyers about the Innocent Spouse rules. If you are liable for tax on a joint return due to income your spouse earned, you may be eligible for relief under the Innocent Spouse provisions. Contact me today.


The Audit Reconsideration is a little known IRS procedure in which the taxpayer gets another chance to prove his case to the IRS. For example:

You never received the IRS Audit Notice;
You failed to provide records the IRS requested;
You failed to respond to an IRS notice of additional tax due;
You didn’t file a return, and the IRS filed a return for you;

In these and dozens of other situations, IRS will simply assess additional tax, penalty and interest and demand payment. The solution can be an Audit Reconsideration, where you present your records to IRS, substantiate your income and deductions and correct your tax liability. I have used the Audit Reconsideration process with great success and saved my clients thousands of dollars of taxes that they didn’t owe. Call me today about this exciting tool for reducing or eliminating your tax liability.


At the beginning of IRS’s Penalty Handbook, a section of the Internal Revenue Manual, IRS states: “In 1955 there were approximately 14 penalty provisions in the Internal Revenue Code. There are now more than ten times that number.” Penalty abatement is available if your late filing, late payment or non-payment of taxes was due to circumstances beyond your control. I have secured penalty abatement for my clients for circumstances ranging from serious illness, death of a close family member, fire, flood or other disaster, even drug and alcohol abuse.


Before IRS can assess additional tax against you, IRS must send you a “Statutory Notice of Deficiency” by certified mail. You have the absolute right to protest the Notice of Deficiency by filing a case in the United States Tax Court, but you must file a Tax Court petition within 90 days after the Statutory Notice of Deficiency date or the Tax Court will not hear your case. Tax Court is a separate federal court devoted exclusively to tax cases, and most Tax Court cases (about 98%) are settled by agreement between the taxpayer and IRS Appeals without a trial. I have filed dozens of Tax Court cases and, while I can’t claim 100% success, I have saved my clients millions of dollars by negotiating very favorable Tax Court settlements, or trying Tax Court cases to a favorable conclusion. If you’ve received a Statutory Notice of Deficiency, Tax Court may be your best alternative.


Most people don’t know that federal and state income taxes can be discharged in bankruptcy as long as the tax debts are old enough and the returns have been on file long enough. I have spent a great deal of time and effort learning the rules about discharging tax debts in bankruptcy, and I have taught bankruptcy discharge rules to other tax professionals. I have also litigated dozens, if not hundreds of bankruptcy discharge issues in Bankruptcy Court and Federal District Court. Find out if your tax debt is dischargeable in bankruptcy