Practice Areas

My practice is primarily concentrated on issues of taxpayer defense. In my practice, I regularly assist clients with all of the following types of matters:

IRS Offers in Compromise
IRS Audit Representation
IRS Appeals
IRS Collection Due Process Appeals
IRS Innocent Spouse Requests
IRS Audit Reconsideration Requests
IRS Payment Plans
United States Tax Court Representation
Bankruptcy Tax Discharge Issues

• IRS Offers in Compromise: The Offer in Compromise is an IRS procedure that gives taxpayers an opportunity to pay a portion of the taxes they owe as full and final settlement, or if the taxpayer disputes that he or she actually owes the alleged tax liability, the Offer in Compromise procedure can be used to have the IRS determine whether the taxpayer owes the liability at all. It is possible to compromise all types of taxes owed to the IRS, including payroll taxes. The IRS accepts approximately 50% of all Offers in Compromise and the average amount accepted is 14 cents on the dollar, so it makes good sense for you to see whether the Offer in Compromise is the right way to solve your tax problem. You may be able to save thousands of dollars. Give me a call today and I can assess your eligibility for the Offer in Compromise.
  
  
• IRS Audit Representation: I have represented hundreds of small business and individual taxpayers in IRS Audits. To be successful in an audit, you must be prepared. You must know how the audit process works, what questions the auditor is likely to ask and how your records should be organized to substantiate your deductions. I know how the audit process works. I know what documents are necessary to support questioned deductions, and I know from experience how to present your information to insure the best chance of success in the audit. I will never present false, fraudulent or frivolous material to the IRS. But I will fight to establish legitimate positions and supportable deductions. If you go into an audit with a shoebox full of disorganized records hoping that the IRS will take the time and put forth the effort to make sense out of the mess, you will lose. Guaranteed! An IRS audit can be one of the most stressful experiences in a person's life. Don't let an inexperienced accountant or return preparer who has no knowledge of your rights or how the audit process works represent you in a tax audit. There's too much at stake. You should hire an experienced tax professional to assist you. Let me guide you through the IRS audit process so you leave the IRS Office with more than just your shirt on your back.
  
  
• IRS Payment Plans: Whether or not you are eligible for an OIC, it is always possible to negotiate and IRS Installment Agreement. IRS Installment Agreements are payment plans in which the taxpayer is allowed to pay the tax debt in manageable installments. The IRS Installment Agreement is a good way to eliminate your tax debt over time and avoid bankruptcy. I have negotiated several hundred IRS Installment Agreements. I can help you come up with an IRS Installment Agreement that is fair and manageable.
  
  
• IRS Appeals: Most taxpayers believe that once their audit is over and the IRS Revenue Agent has prepared the Revenue Agent's Report showing additional tax due, the ballgame is over. It's not. In fact in most cases, the ballgame has just begun. The IRS Revenue Agent cannot do anything more than recommend additions to the tax plus penalties and interest, if appropriate. Once the Revenue Agent has submitted the report, you have an absolute right to appeal the Revenue Agent's findings by filing a written appeal statement with the IRS Appeals Office. The mission of the IRS Revenue Agent is, essentially, to assess the maximum amount of tax, penalty and interest possible (within reason). The mission of the IRS Appeals Office is to settle the case on a fair and equitable basis so the case doesn't have to go to Tax Court. The Revenue Agent will typically resolve all judgment calls (there are always lots of judgment calls in an audit) about income, deductions, credits, etc. in favor of the IRS. IRS Appeals, on the other hand, will typically resolve many of the same issues in favor of the taxpayer. The bottom line is this: You can usually reduce the tax bill and save a lot of money by appealing the Auditor's findings. Let me handle your IRS Audit Appeal. Call me today.
  
  
• IRS Collection Due Process Appeals: Before IRS takes collection action against a taxpayer, such as a bank account or wage levy, the IRS sends the taxpayer a Final Notice of Intent to Levy and Notice of Your Right to a Hearing. The taxpayer has a legal right to file an appeal of the threatened collection action within 30 days of the Notice before the IRS takes money away from the taxpayer. I have filed dozens of collection due process appeals and I am nearly always successful in getting the IRS to accept a monthly installment agreement the taxpayer can afford. In a collection due process appeal, every issue, including whether the tax assessment is valid, is on the table. The collection due process appeal is a powerful tool the law provides to assist taxpayers in getting a fair shake. If you recently received a Final Notice of Intent to Levy and Notice of Your Right to a Hearing, you must act now! Don't let the appeal time expire. Call me today.
  
  
• Innocent Spouse Requests: Innocent Spouse Requests are one of my specialties. I have filed many of them successfully. I have even taught seminars to other lawyers about the Innocent Spouse rules. If you are liable for tax on a joint return due to income your spouse earned, you may be eligible for relief under the Innocent Spouse provisions. Call me today and let's see if you qualify for relief.
  
  
• Audit Reconsideration Requests: The Audit Reconsideration is a little known IRS procedure in which the taxpayer gets another chance to prove his case to the IRS. For example, if you didn't have a chance to get all of your records together, and the IRS lost patience and denied all of your deductions, you can request audit reconsideration, present your records to the IRS, and if your records substantiate the deductions, the IRS will correct your tax liability. I have used the Audit Reconsideration process with great success and saved my clients thousands of dollars of taxes that they didn't owe. Call me today about this exciting tool for reducing or eliminating your tax liability.
  
  
• Penalty Abatement Requests: At the beginning of the IRS's Penalty Handbook, a section of the Internal Revenue Manual, the IRS states:

  "In 1955 there were approximately 14 penalty provisions in the Internal Revenue Code. There are now more than ten times that number."

  Most people don't know that federal and state income taxes more than three years old can be discharged in bankruptcy. I have spent most of my career studying bankruptcy discharge of taxes. And in that time I have litigated dozens, if not hundreds of bankruptcy discharge issues. I cannot be your regular bankruptcy lawyer unless your bankruptcy case is in Oklahoma or Arkansas, but I can and do consult with the taxpayers' regular bankruptcy lawyer on tax discharge issues. I am available to consult with your regular bankruptcy attorney about income tax discharge. If you or your bankruptcy attorney is stumped on a tax discharge question, call me. I can help.
  
  

• Tax Court Representation: If after the audit and appeal of your tax assessment, the IRS is still denying legitimate deductions or ignoring your proof, you have the option of filing a case in the United States Tax Court. Tax Court is a separate federal court devoted exclusively to tax cases. I have filed dozens of Tax Court cases in the past twenty-two years, and while I can't claim 100% success, I have certainly done well representing my clients in Tax Court. If Tax Court is your best alternative, I can help. Call me today.
  
  
• Bankruptcy (tax issues): Most people don't know that federal and state income taxes more than three years old can be discharged in bankruptcy. I have spent most of my career studying bankruptcy discharge of taxes. And in that time I have litigated dozens, if not hundreds of bankruptcy discharge issues. I cannot be your regular bankruptcy lawyer unless your bankruptcy case is in Oklahoma or Arkansas, but I can and do consult with the taxpayers' regular bankruptcy lawyer on tax discharge issues. I am available to consult with your regular bankruptcy attorney about income tax discharge. If you or your bankruptcy attorney is stumped on a tax discharge question, call me. I can help.