Tax Controversy
We are proud of our outstanding record of victories in defending taxpayers audited by the IRS (Internal Revenue Service), FTB (Franchise Tax Board), EDD (Employment Development Dept), DOL (Dept of Labor), Worker’s Comp Board, Cal/OSHA, and State Board of Equalization. Specifically, we
• Defend income tax audits by IRS.
• Defend payroll tax audits by EDD.
• Defend worker reclassification audits (independent contractors) by the IRS and EDD.
• Defend sales tax audits by BOE.
• Defend labor audits by DOL and DIR (Department on Industrial Relations).
• Appeal or request audit reconsideration.
• Apply for Offer in compromise (OIC) to reduce delinquent tax liabilities.
• Request Installment Arrangements (payment plans) with IRS & FTB to buy time for past-due taxes.
• Lift liens on real estate and personal properties.
• Stop levies on bank accounts.
• Stop wage garnishments.
• This is the best forum to settle tax controversies with the IRS.
• Many tax professionals are wary of going to IRS appeals. Not us. We love appeals work.
• Defend payroll tax audits by EDD.
• If you’ve been there, and I have been there many times, you’d rather go there to settle a case rather than go to Tax Court or do battle with an unreasonable agent at the exam level.
• We settle audits to cure your headaches and avoid litigation costs in Tax Court.
• See caption below for “Should you go to Appeals?”
• Appeal or request audit reconsideration.
• Apply for Offer in compromise (OIC) to reduce delinquent tax liabilities.
• Request Installment Arrangements (payment plans) with IRS & FTB to buy time for past-due taxes.
• Lift liens on real estate and personal properties.
• Stop levies on bank accounts.
• Stop wage garnishments.
Having sleepless nights over many years of unfiled tax returns?
Come to us. We’ll process all your delinquent tax returns to stop unwanted penalties and interest.
We’ll even bring multiple years of tax returns at an IRS office in emergency cases.
There’s no reason to keep worrying about unfiled returns.
Penalty for late filing is 5% per month while penalty for late payment is only 1/2 % per month.
Bring your tax records to our office. Let’s get it done!
What you owe the IRS won’t go away. You may as well face it and deal with it.
If you don’t, penalties and interest just keep accumulating.
You think about it week in and week out, and some cases, year in and year out.
You get nervous when an IRS notice arrives, or any certified mail for that matter.
Settle it. Don’t ignore it.
We can help you with either an offer in compromise or a payment plan.
Please read A-Z Tax Tips and captions for OIC payment plans below.
We are proud of our success in setting up offers in compromise (OIC) for taxpayers who are unable to pay delinquent taxes.
We analyze the advantages and disadvantages of applying for OIC in your particular case.
Advantages: If the offer is accepted, you will be left alone; tax liens will be removed, enforced collection avoided. Acceptance of an adequate offer relieves you of a financial burden and gives you a fresh start toward compliance with your future filing and payment requirements.
Disadvantages: You must list all your assets. In the process, you are giving them a roadmap to seize and sell your assets if the offer is not accepted and nothing else works. One missed payment results in a default that gives the IRS the right to resume collection. You must comply with all provisions relating to the timely filing of returns and payment of taxes due for the next five years.
Settle it. Don’t ignore it.
We can help you with either an offer in compromise or a payment plan.
Read A-Z Tax Tips below for more information on this subject.
Can’t pay your tax bills? Can’t qualify for an OIC?
If so, we can arrange a payment plan suited to your budget.
Come to us so we can analyze your situation.
Let’s first do a preliminary analysis if you are a good candidate for a payment plan.
If you apply before you analyze, you may just waste money to prepare financial statements.
We are also proud of our success in helping taxpayers survive financial hardships.
If your payment plan is approved, behave. You cannot go back to your old ways of neglecting your tax duties. Follow rules; otherwise, the plan defaults and you have a harder time next time.
• Mail your payments to be received on time. The monthly due date is the date of receipt at the IRS Service Center, not the date of mailing. Calendar mailings three days before.
• Use certified mail with return receipt.
• Do not skip one payment and double up on the next payment. One skipped payment causes the entire installment agreement to default.
• Make each payment in the exact amount of the agreement. If you have to pay a different amount, pay more but not less. Paying less is equivalent to a missed installment that is in violation of the agreement and therefore will also cause the entire agreement to default.
• Enclose a reminder notice from the IRS with your first payments. If you do not receive a notice to pay (especially in the first month or two), attach a copy of Form 9465 or 433-D Installment Agreement with your check; otherwise, the IRS will apply to other liabilities.
• Write your Social Security Number (or federal I.D. number for business) on top of your check (preferably in red).
• Write "Installment #1", then "Installment #2" on the lower left-hand corner of your check. This helps both you and the IRS to keep track of your payments.
• Make your check payable to the Department of Treasury and mail that check and notice to the IRS address written in Form 433-D (Do not rely on old addresses. The recent reorganization transferred mailing addresses to different area centers).
• Mail a copy of your check and the notice to your accountant and file your copy to a manila folder labeled "IRS Installment Agreement."
• Read Tax Tips below for more information on this subject.
• If you fail to pay an assessment, a federal tax lien arises and attaches to your properties.
• The lien attaches to all properties and property rights - real or personal.
• It attaches to properties owned on assessment date as well as properties acquired after the lien is filed.
• You cannot sell or refinance assets subject to a lien.
• We study your case to find a solution to lift the lien.
• Liens pose a problem if you refinance an existing loan or buy or sell real estate.
• The lien has to be paid first and released before escrow can close.
• Here is some relief - IRS recently announced an expedited process that will make it easier to prevent a federal tax lien from blocking the refinance or sale of a home.
• If no action is taken to pay or abate the assessment, the lien exists for a 10 year collection statute.
• If you still do not take care of the lien, IRS files a levy to seize your property.
• Up until then, the lien merely encumbers your property which cannot yet be seized by the IRS.
• The IRS can file a levy to actually seize your property.
• The IRS can also collect from 3rd parties such as banks and customers.
• Read A-Z Tax Tips below for more information on this subject.
• Wage garnishments are form of levy against your paycheck.
• Wage levies indicate neglected tax responsibilities.
• It could be a sign of financial hardships or simply sheer negligence. Or both.
• It creates an uncomfortable situation with your employer.
• Face the problem. Work out an arrangement.
• We have successfully dealt with the IRS and other agencies to lift wage garnishments.