A taxpayer owes the IRS more than he can pay in a lump sum. He owns a home. He owns a business property. He has some equity in both. He asks the IRS for an installment agreement so he can pay the debt over time. The IRS says no. The reason? He has too much…
Category: Tax Litigation
Tax Litigation
Tax litigation involves disputes between taxpayers and the IRS that are resolved in court. We help clients navigate tax litigation and protect their rights. Give us a call to see how we can help, (713) 909-4906.
Can Your Business Deduct Credit Card Interest When the Card Is in Your Name?
Small businesses often struggle to get credit. Banks want collateral, financial history, and revenue figures that newer or smaller operations cannot always produce. When the business itself cannot qualify for a loan or a credit card, the owners step in. They open credit cards in their own names, charge business expenses to those cards, and…
Can the IRS Ignore Your Request for an Estate Tax Valuation Explanation?
When a family member dies and leaves behind interests in a closely held business, the estate has to figure out what those interests are worth. This is rarely straightforward. There is no ticker symbol, no public market, no closing price to look up. The estate hires an appraiser, applies valuation methodologies, and reports a number…
Can the IRS’s Automated System Issue a Valid Notice of Deficiency?
Every year, millions of taxpayers receive letters from the IRS proposing adjustments to their tax returns. Most people assume those letters came from a human being who reviewed the file, weighed the facts, and made a considered decision to send the notice. That assumption is increasingly wrong. The IRS relies heavily on automated systems to…
Who Gets the Tax Credit When You Outsource Payroll to a PEO?
Many businesses outsource their payroll, human resources, and employment tax responsibilities to professional employer organizations. These arrangements make sense. The PEO handles the administrative burden of onboarding workers, processing wages, withholding taxes, and managing benefits. The business owner focuses on running the business and directing the workers. But when it comes time to claim employment-related…
Can Corporate Suspension Foreclose U.S. Tax Court Review
There are a number of administrative rules that businesses have to comply with. This can create administrative headaches for businesses–particularly small businesses. The requirement for annual maintenace of state corporate status is an example. Businesses, particularly small businesses, often fail to meet annual state filing requirements. The result is that their corporate powers are limited.…
When the IRS Levies Estate Property, Whose Fight is it?
When a taxpayer dies with unresolved IRS issues—unpaid taxes, disputed levies, or unrefunded overpayments—the family often assumes that whoever inherits the estate can pick up where the decedent left off. That assumption might not be the correct. The tax code gives specific rights to specific parties. When the wrong person shows up in federal court…
Can a Tax Attorney Recover Attorney’s Fees from the IRS for their Own Case?
The IRS administrative process is intended to catch incorrect tax returns and make adjustments to fix the returns. This includes false and fraudulent tax returns as well as those with honest errors. This includes an IRS audit function, and IRS appeals function, and IRS counsel function. And each step has a management oversight function and…
COVID-19 Extended Tax Deadlines Longer Than Many Realized
Taxpayers have various tax filing deadlines throughout the year. Missing one can trigger penalties, interest charges, and collection actions. When there is a major disaster, the IRS typically grants short extensions to give affected taxpayers breathing room. During the COVID-19 pandemic, the IRS issued notices extending various tax deadlines by a few months. The agency…
Qualified Offer Delivery: “Addressed To” vs “Delivered To”
You’ve done everything right in working with the IRS and the IRS still got it wrong. You’ve exhausted your administrative remedies and you have to hire a tax attorney. Now you are incurring costs just to correct the IRS error. The attorney has you make a proper qualified offer under Section 7430(g) to recover attorneys…