Tax Representation

Navigating the myriad of taxation in today’s complicated world can be a difficult task for even the most knowledgeable business person. There are times when problems develop where professional advice and representation is the only good alternative. This is most important when a dispute arises between the government and an individual concerning alleged tax liability and collection.

The Business Taxpayer

From beginning to end, all businesses generate the real possibility of unplanned tax liability.  Businesses are usually impacted by several types of tax liability claimed by multiple government agencies at the federal, state and local levels. These taxes include income tax, excise taxes, sales and use tax, property tax, payroll tax, unemployment tax, license tax and net profits tax.  Your business is liable for each of these taxes to one or more government agencies if your business:

1) Is located in an identifiable location; Is located in an identifiable location;

2) Employs or contracts with individuals for their labor;

3) Purchases tangible property; and

4) Sells tangible property to others in the course of your business.

How you plan your business tax profile and organize your business to pay these taxes determines the success of your business enterprise. We can help you develop methods of complying with tax liability required by many of the governmental units that have authority over your business. You also need to understand the tax consequences to your business resulting from how your business is structured.

The Individual Taxpayer

The most common tax problems for individuals are as varied as the revenue codes that effect their possible tax liabilities and benefits. Disputes with the IRS and with state revenue departments can include:

• Disallowed deductions;
• Incorrect filing status; and
• Insufficient documentation to support tax returns filed.

Investments and property transactions may affect your tax liabilities. Planning these transactions is essential to keeping your tax liabilities at a minimum.

An increasing problem today’s complex and mobile society is unfiled tax returns. Individuals, who lose employment, undergo a serious disruption in their family life, or move often, may lose track of the means and documentation that would enable them to file annual income tax returns required by the IRS or a state department of revenue. We can help you file those returns and assist you in making settlement of accrued liability.

Past Due Tax Liability

Congress has enacted methods for settlement of past due tax liability. These may include penalty abatement, installment payment plans, lien subordination, removal of tax liens and offer in compromise. There are also ways to settle state and local tax liability established by statute, ordinance and regulation. Individuals and businesses are often unable to pay all taxes, penalties and interest accrued on an account with a government agency and professional assistance is the most effective way to solve these legal and financial problems. 

Our firm can represent your business before the IRS, at the audit, administrative, appeals, and litigation levels. Our services also include representation before and against local and state agencies for taxation.

Offer in Compromise

An offer in compromise (OIC) is an agreement between a taxpayer and the IRS that resolves the taxpayer’s tax liability. The IRS has authority to settle or compromise federal tax liabilities by accepting less than full payment under certain circumstances. The IRS may legally compromise for one of the following reasons:

1) Doubt as to liability;

2) Doubt that the assessment of tax is correct;

3) Doubt as to collectibility; or

4) Effective tax administration. (Under effective tax administration, there is no doubt the assessment is correct and no doubt the amount owed could be collected, but the taxpayer has an economic hardship or other special circumstances that may allow the IRS to accept less than the balance due.)

Our firm will review your financial information, assist you in making an offer based upon your “reasonable collection potential” (RCP) as defined by regulations, and help you file and defend your offer before the IRS at the OIC level, upon appeal and, if necessary, in litigation before the United States Tax Court.

Initial Consultation and Fees

Within reasonable limits, there is no charge for the initial contacts and the first exploratory consultation. The firm will discuss fee options for certain tax representation services available.  In addition we work with our clients on mutually agreed upon payment schedules and we accept most major credit cards upon approval.