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IRS Tax Controversy & Litigation

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 Status

For 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 Matters

When 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 Relief

Innocent 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)

Tax Litigation (Notice of Deficiency)

The firm helps sustain client's 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 Reconsideration

An 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.