Our firm has represented thousands of individuals and business with tax related problems with the Internal Revenue Service and/or State taxing agencies. We have provided assistance in the following areas:

* 940/941 Employment Taxes

* Trust Fund Recovery Penalty (civil penalty)

* Tax Audits

* Workers' Compensation Audits

* State Tax liabilities 

    * Sales Tax 

    * Employment Tax 

    * Income Tax

* IRS Offers in Compromise

* State Offers in Compromise

* U.S. Tax Court representation

* Innocent Spouse Claims

* Wage garnishments/levy

* Collection Due Process Hearings

We are a full service law firm providing aggressive representation in all tax related matters.

OFFERS IN COMPROMISE

Over the years, we have enjoyed significant success in utilizing the Federal and State Offer in Compromise programs. The Offer in Compromise program allows individuals and businesses to retire delinquent tax liabilities for a fraction of the amount owed. The amount required to satisfy a past due tax liability is not based on the amount owed. The basis for a "fair offer" is determined on the ability of an individual or business to pay. Information is submitted to the IRS or State tax agency for a complete financial analysis. Prior to any information being submitted, we complete a financial analysis of our client. In fact, we pre-qualify our clients for the Offer in Compromise Program before submitting an offer. This pre-qualification program has resulted in our success rate of approximately 90%. We will not put a client in the Offer in Compromise Program if we do not believe there is a possibility of success. Instead, we will pursue other alternatives in an attempt to assist the client.

There are certain requirements before an Offer in Compromise can be submitted: 

    - All tax returns due must be filed. 

    - Any estimated tax due for the year in which an Offer in Compromise is submitted must be current. 

    - For existing businesses, all tax returns must be filed and employment tax liabilities must be current for the two (2) quarters preceding the submission of the Offer in Compromise.

We charge a reasonable fee for submission and representation in regards to Offes in Compromise. Attorneys will handle all aspects of your tax case. You will not be left in the hands of a legal assistant or clerk. The attorney will also be accessible by phone or e-mail to speak with you. We provide personalized attention. Examples of our recent successes in the Offer in Compromise Program are included in this web site.

940/941 Taxes

We have represented a multitude of businesses who have fallen behind in the payment of 940/941 employment taxes. In the majority of cases, we have been able to submit certain finacial verification (after our own analysis) and establish an installment agreement with the IRS which allows our client to remain in business. If the installment agreement payments are made as agreed, and all current taxes are paid in a timely manner, the IRS will not take any action against the business to collect the tax owed. It is on the rare occassions that one of our business clients has been closed through IRS seizure of assets.

TRUST FUND RECOVERY PENALTY

The Internal Revenue Service is authorized by I.R.C. Section 6672 to assess responsible parties of a corporation for the withheld portion of employment taxes which are not paid to the governmnet. The withheld portion includes the employee portion of social security and medicare and income tax. Once the IRS has assessed responsible parties, they can then proceed to collect the unpaid employment taxes against the assessed individuals. Our firm has provided representation in numerous cases involving assessment of the Trust Fund Recovery Peanlty against individuals associated with a coporation with delinquent emmployment taxes. Our representation in this area has included: Offers in Compromise, Appeals of a proposed Trust Fund Recovery Penalty assessment, Request for Refund/Abatement and refund/abatement suits against the Internal Revenue Service/United States Treasury in U.S. District Court. We have enjoyed significant success in this area.

TAX AUDITS

We have represented numerous clients under audit. Our representation has included: involvement in the actual audit, appeal of the auditor's determination, Tax Court filings concerning the auditor's findings and a notice of deficiency and preparation of amended returns and deliquent returns. In fact, we hava assisted a number of clients by preparing and filing 8-12 years of delinquent returns.

STATE TAX ISSUES

Our firm provides representation in matters concerning taxes owed to State taxing authorities. These agencies would include the Department of Taxation, Workers' Compensation and unemployment taxing agencies. Many states have instituted an offer in compromise program similar to the IRS Offer Program. Although some states do not have a formal offer in compromise program, it is still possible to negotiate a reduced payoff of liabilities due. In cases in which an offer in compromise or reduced lump sum payoff is not possible, we have been able to negotiate installment agreements on behalf of our clients which are not burdensome. Once the installment agreement has been finalized, state taxing agencies will not take any seizure action against the assets of the taxpayer so long as payments are made as agreed and all current taxes are paid in a timely manner.

WAGE GARNISHMENTS/LEVY

We see numerous individuals and business after the IRS has garnished their wages, seized bank accounts, etc. We are able to obtain a release of the levy/garnishment if certain criteria is met. All tax returns due must be filed. Further, the taxpayer must be making a resonable effort to address the tax liability. It is our experience that if these conditions are met, the IRS will release the levy for a period of time while counsel is working on the case. In some instances, we have bene able to obtain a levy release when all tax returns had not been filed as the promise to file the deliquent returns within 30-60 days. If the IRS refuses to release the levy/garnishment, or takes any other colection related activity against the taxpayer which we deem to be improper, we simply file a Request for Collection Due Process Hearing and the case is referred to an appeals officer. It has been our experience that the majority of the cases referred to the Appeals Division of the IRS are resolved in a manner satisfactory to our client.