Tax Resolution & Controversy
CRITICAL NOTICE: Received an IRS CP2000, Statutory Notice of Deficiency (90-Day Letter), or Notice of Intent to Levy? You have strict statutory deadlines to respond before enforcement actions begin.
We provide strategic representation for audits, back taxes, bank levies, and federal tax court litigation. We step directly between you and the IRS to protect your rights, capital, and future.
Comprehensive Defense During Field & Office Audits
Facing an IRS audit without specialized representation puts your financial security at risk. We manage all agency communications, substantiate reported income and deductions, and defend your positions during desk, office, or field examinations to minimize tax exposure and block revenue agents from expanding the audit scope.
Key Deliverables: Field & Correspondence Audit Representation, Substantiation & Document Preparation, Scope Limitation Strategies.
IRS Appeals & Audit Reconsiderations
Challenge Unjust Audit Findings & Dispute Deficiencies
An unfavorable audit assessment is not the final word. We file formal administrative protests through the IRS Independent Office of Appeals and submit Audit Reconsideration requests backed by newly discovered financial records or legal misapplications to overturn erroneous tax assessments.
Key Deliverables: Formal Appeals Officer Conferences, Audit Reconsideration for Default Assessments, Penalty & Interest Reversals.
Tax Debt Relief (Offers in Compromise & Installment Agreements)
Negotiate Feasible Settlements & Payment Plans
Settle your federal and state tax liabilities for a fraction of what you owe through an Offer in Compromise (OIC) if you meet strict financial qualifications. Alternatively, we negotiate structured Partial Payment or Streamlined Installment Agreements designed to align with your real-world business cash flow.
Key Deliverables: Offer in Compromise (Doubt as to Liability / Collectibility), Partial Payment Installment Agreements (PPIA), Collection Due Process (CDP) Hearings.
Penalty Abatement Requests
Eliminate Compounding Penalties & Interest Charges
IRS failure-to-file and failure-to-pay penalties can inflate your tax debt exponentially. We submit targeted administrative petitions for First-Time Penalty Abatement (FTA) or establish Reasonable Cause (such as serious illness, casualty losses, or reliance on erroneous tax advice) to eliminate accrued penalties.
Key Deliverables: First-Time Administrative Abatements, Reasonable Cause Legal Petitions, Interest Restructuring.
Innocent Spouse Relief
Shield Yourself from a Spouse’s Tax Liabilities
Under IRC § 6015, you should not be held liable for tax understatements, understated income, or fraudulent claims made by a current or former spouse. We prepare comprehensive filings for Innocent Spouse Relief, Separation of Liability, or Equitable Relief to insulate your personal assets from joint liabilities.
Key Deliverables: IRC § 6015(b) & (c) Separation Claims, Equitable Relief Petitions (§ 6015(f)), Personal Asset Protection.
Injured Spouse Relief
Protect Your Share of a Joint Tax Refund
If your share of a joint income tax refund was seized by the IRS to satisfy your spouse’s past-due obligations—such as child support, federal student loans, or prior individual tax liabilities—we file Form 8379 to calculate and recover your rightful allocation of the refund check.
Key Deliverables: IRS Form 8379 Allocation Filings, Refund Protection, Revenue Allocation Audits.
Levy & Garnishment Release
Stop Immediate Wage Seizures & Frozen Bank Accounts
An active IRS bank levy or wage garnishment can freeze operating capital and paralyze your personal finances. We intervene immediately with Revenue Officers and IRS Automated Collection System (ACS) representatives to secure immediate releases by establishing alternative resolution pathways.
Key Deliverables: 24–48 Hour Emergency Levy Releases, Wage Garnishment Modification, Business Payroll Unfreezing.
Lien Withdrawal or Subordination
Clear Title & Unlock Asset Refinancing
A Notice of Federal Tax Lien impairs creditworthiness and restricts real estate financing. We petition the IRS for Lien Withdrawal to remove public records entirely, or Lien Subordination to allow refinancing or asset liquidations that directly reduce your tax debt.
Key Deliverables: Form 12277 Lien Withdrawal Petitions, Mortgage & Commercial Loan Subordinations, Lien Discharges.
Currently Not Collectible (CNC) Status
Halt All IRS Collection Actions via Hardship Status
When repaying tax liabilities creates severe economic hardship, we present certified financial verifications to place your account into CNC status. This immediately halts all collection activities, bank levies, and garnishments while the statutory 10-year collection clock continues to run.
Key Deliverables: Form 433-A / 433-B Financial Statement Defense, Freeze on Collection Enforcement, 10-Year Statute Expiration Monitoring.
U.S. Tax Court Representation
Formal Federal Litigation & Petition Filing
When administrative negotiations reach an impasse, filing a petition before the U.S. Tax Court following a 90-Day Notice of Deficiency is critical. We litigate your dispute in federal court prior to payment, protecting your right to judicial review without prepaying disputed taxes.
Key Deliverables: Tax Court Petition Filings, Pre-Trial Appeals Negotiations with IRS Counsel, Federal Bench Trial Representation.