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IRS and State Tax Defense/Representation

While it is our goal to find a permanent solution to your entire tax problem, sometimes short-term relief must be accomplished before long-term amnesty can be realized.

If the IRS has already placed an income source levy (garnishment) against you, then immediate representation is needed in order to achieve a release of the levy. This can often times be done within a day or two. In order to secure a release, full tax filing compliance must generally be secured and then approved payment arrangements must be secured from the IRS or evidence must be provided to demonstrate that payment arrangements are not affordable at this time.

If the IRS has assigned your tax case to a Revenue Officer, then immediate representation is needed in order to avoid continued or future enforcement. Generally, an IRS Revenue Officer will also want to get you back into full tax filing compliance and will then want to secure your collection information statement(s) so a determination can be made about what you can afford to pay toward the tax debts owed.

Other times, a levy may not yet be issued by the taxing authorities and a revenue officer might not yet be assigned, but tax defense/representation may still be the service that you need. For example, if:

• your collection statute expiration date (CSED) is not going to pass anytime soon;
• you don't qualify for any of the innocent spouse relief programs;
• you aren't a good candidate for an offer-in-compromise (OIC) settlement;
• you don't qualify for penalty abatement and/or you aren't willing or able to pay off your taxes net of penalty abatement; and
• you don't stand to benefit from or don't want to file bankruptcy,

then representation before the IRS and/or state taxing authorities to keep them from enforcing themselves upon you may be the only short-term option available to you.

Typically, our representation of you before the taxing authorities will end in one of the following ways:

• finding a way to help you remit full payment of the taxes;
• securing an installment agreement payment plan to make payment of the taxes affordable;
• securing a "partial-pay" installment agreement for a lower monthly amount than what is really needed to full pay the taxes within the remaining collection statute;
• securing a "specific-period" installment agreement wherein installment payments are applied to one particular account out of many that may be owed; or
• securing "currently not collectible" status wherein the taxing authorities agree that you are not capable of remitting payments at this time and agree to put your case on hold without collection threats for some indefinite period of time.

Short-term representation may have to be implemented until one of the permanent resolution programs works better sometime down the road to ultimately resolve the tax debts.

To summarize, tax defense/representation is an immediate requirement if there is a levy issued or an IRS revenue officer assigned to a case. It can be a permanent resolution if an installment agreement is set up to full pay the tax liabilities over time. Otherwise, it is a short-term mechanism for awaiting one of the five permanent resolution programs to become a workable option for resolving the liabilities owed in full.

If you need representation before the IRS or your state taxing authority, please contact our office for help.