Taxpayer Resolution Services

 
 

Taxpayer Resolution Services

 
 

Assessment Issues

Audit Representation Our tax attorneys represent clients in audits and examinations with the IRS and state taxing authorities. We aggressively present each client’s position and challenge the contrary positions taken by the taxing authorities. We advise our clients clearly about the issues under consideration and help them to decide which ones to contest and which ones to concede.   

Settlement Conferences and Appeals:  If there are unresolved issues after the audit process, we help our clients pursue their positions in settlement conferences and appeals. These proceedings require careful legal analysis but can often produce favorable results for our clients.
 

Collection Issues

Payment Agreements:  We help our clients negotiate payment agreements that work. Our goal is to help clients address their tax obligations in a manner that allows their businesses to continue to operate and minimizes the disruption to their personal lives.

Offers In Compromise/Settlement: Our tax attorneys assist clients with the preparation and filing of compromise requests. These requests require careful analysis of the nature and extent of a client’s assets, the type of tax liabilities at issue and the relevant collection statutes. When the request has been submitted, we work with our clients to respond to questions about the request and to negotiate proper payment terms for the compromised liability.

Prevention of Property Seizure:  We work with clients to resolve tax matters before property is put at risk. Our clients can often protect their property by properly asserting their legal rights before tax issues reach the point where tax authorities attempt seizure, and we help guide clients through this process.

Collection Appeals:  Our tax attorneys often protect clients from unreasonable collection action by asserting their rights to appeal. The appeal process can defer or prevent collection and may help clients obtain a more favorable resolution.

Release of Tax Liens and Levies:   The seizure of a client’s bank account or other attachment of property can interfere with cash flow, make it impossible to obtain credit and otherwise disrupt a client’s business or personal life. When our clients have had their property attached, we can often help them obtain releases and make other arrangements to address their tax liabilities.
 

Employment Issues

Employment Tax Assessment and Collection:  The IRS and other taxing authorities can take rigid positions with respect to assessing and collecting taxes related to employment, ranging from the characterization of compensation and classification of employees and independent contractors, to imposing strict requirements for the collection and payment of employment taxes. We assist our clients and their employees with determining their employment tax obligations and with negotiating reasonable resolutions to employment tax matters.

Trust Fund Penalties:  The IRS is particularly aggressive in imposing penalties on employers for failing to collect or pay employment taxes. We frequently assist business owners in contesting these assessments and in contesting the classification of other executives as responsible parties, also eligible for the imposition of the trust fund penalty. We also represent our clients in collection matters arising from the imposition of penalties and in negotiating claims against other owners and executives with joint liability for the penalties.
 

Divorce and Innocent Spouse

Alimony/Property Settlement Matters:  We assist our clients with tax matters that arise from the division of property pursuant to a divorce and post-marital support payments.

Innocent Spouse Claims:  Our tax attorneys help clients work through the complex rules that govern claims for relief from liability for the tax obligations of a current or former spouse. We clearly advise our clients on the process for filing claims and on the factors that are important in making a determination on a relief request. We also help our clients address tax obligations while the relief claims are pending and negotiate resolution of the relief claims with the IRS and tax authorities.
 

Civil and Criminal Matters 

There are some matters that cannot be resolved at an administrative level with the IRS or other taxing authorities. We represent clients in various tax forums, ranging from civil federal matters at the U.S. Tax Court and the U.S. District Court to Massachusetts matters at the Appellate Tax Board and the Appeals Court. We also represent clients with potential criminal exposure arising from tax issues.

 
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