Type of Dispute
Often clients acknowledge they owe taxes but are simply unable to pay. There are almost always resolutions of these tax collection problems that the client can live with. We handle all contact and communications between the client and the tax agency, and work to obtain an acceptable solution through the use of financial analysis and knowledge of applicable procedures. These resolutions typically involve: (1) installment agreements, (2) offers in compromise, or (3) discharging taxes in bankruptcy. One of the most significant developments in IRS collection cases was the 1998 implementation of administrative and judicial appeals through the collection due process (CDP) rules. CDP appeals often present the best opportunity to reach an acceptable installment agreement or offer in compromise for complicated collection issues.
Virtually all of our professionals have worked extensively with the collection divisions of the IRS, FTB, EDD and BOE. Jim is a former IRS Collection Division employee. Steve is co-author of the two BNA Tax Management Portfolios on tax collection. These are the most widely circulated treatises on IRS collection in the country. Lydia handled an extensive docket of tax collection litigation with the Department of Justice. Steve, Lydia and Jim have all handled dozens of collection appeals with the IRS Appeals Office and Steve has probably tried as many CDP cases as anyone in the country.