IRS Tax Controversy & Litigation
Call (206) 447-7766
to schedule a phone consultation with an experienced Tax Attorney
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Attorney Endorsements
Background
For over twenty (20) years, Andrew J. Wyman’s practice
has consisted primarily of representing taxpayers in front of the
Internal Revenue Service and litigating federal tax cases in front
of the United States Tax Court. Andrew started working in private
practice after working for the Office of Chief Counsel for the
Internal Revenue Service, litigating cases in front of the United
States Tax Court, and advising internally on audit and collections
matters.
Andrew’s tax practice continues currently in
private practice, offering his skills, knowledge and insight in a
variety of federal tax matters, representing individuals and
businesses against the Internal Revenue Service (IRS) and
representing taxpayers in front of the United States Tax Court.
Areas of Practice
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IRS
Tax
Controversy
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IRS
Tax
Litigation
Litigation Percentage
Bar Admissions and Associations
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New York Bar Association 2000
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Washington State Bar Association, 2002
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East King County Bar Association
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U.S. District Court, Western District of
Washington
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U.S. Tax Court
Education
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Georgetown University Law Center, 2000, LL.M.
Taxation.
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Georgetown University Law Center, 2000, LL.M.
International & Comparative Law.
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Gonzaga University School of Law, 1998, J.D.
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Eastern Washington University, 1992, BA in
Business Administration (Finance, Econ).
IRS Collection Defense
As you hopefully expect, IRS
Collection Defense is more than just Settlements and Offers and
Compromise. Wyman Law Firm help you work through the maze of
option and pick the best remedy that can be sustained against
challenges made by the IRS. Here is a list of several possible
remedies that may be used for such relief:
Installment Agreements (Partial Payment)
Installment Agreements are often
overlooked and undervalued by taxpayers who owe the IRS. In
many cases, installment agreements can lead to better results than
the famed "Offer in Compromise" (or "$.10 on the Dollar," as
seen on TV). Wyman Law Firm will determine whether such is the
case for you, looking at options with installment agreements to
avoid liens, and have your expenses that exceed IRS standards
allowed as conditional expenses. Wyman Law Firm will also seek
to negotiate payment terms that will result your paying less than
the full amount of tax due.
Currently Not Collectible
StatusFor those who
do not have the resources to pay their taxes, Currently Not
Collectible standard is an excellent way to avoid having to pay your
taxes, and the deferral is generally one year or more.
IRS Bank and Wage
Levies (Garnishments)
Using a combination of the remedies listed herein, Wyman Law Firm
can help you find the best and quickest route to having IRS Bank and
Wage Levies (Garnishments) removed. IRS Notice of
Federal Tax Lien (NFTL)
IRS Liens are public records that can cause embarrassments,
financial hardship, and credit issues. Reasonably, most people
want them remove as quickly as possible. With several of the
remedies listed herein, Wyman Law Firm can quickly and painlessly
remove an IRS Lien. Unfortunately, with complicated tax
matters, having an IRS lien removed takes tenacity, knowledge, and
ingenuity to have an IRS Lien removed. The attorneys at Wyman
Law Firm have such skills and would be happy to work with you to
have such a lien removed.
Collection Due Process Hearings (and Appeals)
Many IRS remedies have the ability to
have low level decisions reconsidered by IRS Appeals Officers.
To obtain the best results, filing the Hearing Request, Protest, or
Appeal is the best way to seek optimum results. Penalty Abatement
The penalties the IRS assesses can be
expensive. Combined, they can often be be fifty percent (50%)
or more of the tax assessed. The common penalties include
Estimated Tax Penalty, Failure to File Penalty, Failure to Pay
Penalty, Accuracy Related Penalty (Negligence), and the Trust Fund
Recovery Penalty. During the course of representation, the
Wyman Law Firm makes a point to see reduction of penalties, and,
under the right circumstances makes additional filings to have these
penalties abated.
Bankruptcy Planning For Tax MattersWhen
you are forced to file Bankruptcy, it is generally your last resort.
It is imperative that your plan ahead, so you can discharge as many
taxes as possible. Unfortunately, not all types of federal
taxes (IRS) can be discharged, and, even if a type of tax is
dischargeable, there are several waiting periods you must meet to
maximize the amount of taxes discharged. With property
planning, combined with the use of some of the above techniques,
Attorney Wyman can help you maximize the amount of taxes discharged
in bankruptcy, leaving you with little to no balance after discharge is
granted.
Innocent Spouse
ReliefInnocent
Spouse Relief is a complicated are of the Tax Code that is provided
to Innocent Spouses who are harmed by joint tax balance. Wyman
Law Firm can help you have the Innocent Spouse rules applied to
leave you free and clear of such liability that was caused by your
spouse (or ex-spouse) Offer in
Compromise ("Doubt as to Collectability")Using IRS
procedure to have the IRS compromise (reduce) your liability by
establishing that there is doubt that the the IRS can legally
collect such before the expiration of the Collection Statute of
Limitations (CSED). (click
for more)
Offer in
Compromise ("Doubt as to Liability")
Using IRS procedures to have
tax liability, including interest and penalties, compromised based
on a factual argument that you do not owe the liability. (click
for more)
IRS
Audit Defense
Representation During IRS
Examinations (Audits)
Respond to Correspondence Audits
Tax Litigation (Notice of
Deficiency)
The firm helps sustain clients’ position in federal tax disputes
by assisting with compliance and disclosure obligations, and
representing them in audits, administrative appeals, and litigation.
The firm can also assist you in obtaining private letter rulings
from the IRS related to proposed transactions and also renders its
own opinion regarding tax consequences.
Refund Claims & Suits (Federal District Court)
Representation During IRS Appeals
Resolve IRS Tax Liabilities
Unfiled Tax Returns (Substitute for Return)
IRS
Audit ReconsiderationAn
Audit Reconsideration is an procedure to challenge an assessment
placed on a taxpayer's account by the IRS after an audit or after
the IRS calculates the taxpayer's taxes by preparing a Substitute
for Return (see below). There are often preferable options to
an Audit Reconsideration. However, in applicable cases, the
Audit Consideration is a invaluable tool for resolving tax
liability.
IRS Payroll Tax (Employment Tax) Liability
Trust Fund Recovery Penalty (TFRP)
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Bellevue Law Office
1400 112th Ave SE, Suite 100
Bellevue, WA 98004
info@wymanlegal.com
(206) 447-7766
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