Tax Law Attorneys — Federal, State & Local Tax Resolution

Tax problems rarely stay simple. A single unfiled tax return, an unexpected IRS audit notice, or a missed payment can quickly grow into penalties, interest, tax liens, wage garnishments, or bank levies. The tax attorneys at Premier Legal Solutions LLC help individuals, small business owners, corporations, and nonprofit organizations understand where they stand, what their options are, and how to resolve tax matters at the federal, state, and local level.

Whether a matter involves the Internal Revenue Service (IRS), a state department of revenue, or a local taxing authority, our approach is the same: assess the exposure, identify the available relief, and pursue the tax resolution strategy best suited to the client’s circumstances.

IRS Audit Defense and Examination Representation

Being selected for an IRS audit does not mean wrongdoing occurred, but how a taxpayer responds can significantly affect the outcome. Our IRS audit lawyers represent clients throughout the examination process, including:

• Correspondence audits conducted by mail
• Office audits at an IRS location
• Field audits at a home or place of business
• Employment and payroll tax audits, including worker classification (employee vs. independent contractor) examinations

We work to limit the scope of an examination, respond to Information Document Requests (IDRs) appropriately, and protect our clients’ rights throughout the audit process — including appealing proposed adjustments when the examiner gets it wrong.

IRS Appeals: Collection Due Process (CDP) and CAP Hearings

When a taxpayer disagrees with a proposed IRS action, the IRS Independent Office of Appeals often provides an avenue for resolution short of litigation. We represent taxpayers in:

• Collection Due Process (CDP) hearings, typically available in response to a Notice of Federal Tax Lien filing or a Final Notice of Intent to Levy
• Collection Appeals Program (CAP) hearings, a faster, though more limited, avenue to challenge certain IRS collection actions
• Equivalent hearings, for taxpayers who miss the CDP deadline but still want Appeals review
• Audit reconsideration and appeals of proposed deficiencies and other IRS determinations

U.S. Tax Court Litigation

When a tax dispute cannot be resolved administratively, taxpayers may have the right to petition the United States Tax Court. Our tax litigation attorneys represent clients in Tax Court proceedings involving disputed deficiencies, collection due process determinations, innocent spouse claims, and other matters within the court’s jurisdiction — guiding clients through petition deadlines, pretrial procedure, and, where appropriate, settlement negotiations with IRS Chief Counsel or trial.

Tax Debt Relief and Resolution Strategies

Owing back taxes does not mean there is only one path forward. Depending on a client’s financial circumstances and the nature of the liability, we evaluate and pursue tax debt resolution options such as:

• Installment agreements — including streamlined, partial-pay, and non-streamlined IRS payment plans
• Offers in compromise (OIC) — settling tax debt based on doubt as to collectibility, doubt as to liability, or effective tax administration
• Currently not collectible (CNC) status — a collection hold for taxpayers experiencing financial hardship
• Penalty abatement — including first-time penalty abatement and reasonable cause relief, where failure to file, pay, or deposit resulted from circumstances beyond the taxpayer’s control
• Innocent spouse relief — for individuals seeking relief from liability arising from a spouse’s or former spouse’s erroneous items
• Interest abatement — in limited circumstances involving IRS error or delay
• Trust Fund Recovery Penalty (TFRP) defense — for business owners, officers, and employees facing personal liability for unpaid payroll taxes
• Unfiled tax return compliance — bringing non-filers back into compliance strategically before enforcement escalates
• Statute of limitations analysis — determining whether collection or assessment periods have expired
• Bankruptcy and tax discharge analysis — evaluating whether certain tax debts may be dischargeable, in coordination with bankruptcy counsel where appropriate

Tax Liens, Levies, Garnishments, and Seizures

Federal and state tax enforcement actions can affect your credit, bank accounts, wages, accounts receivable, and real estate. We help clients:

• Prevent enforcement before it happens through proactive resolution
• Obtain release of bank levies and wage garnishments
• Pursue lien withdrawal, release, subordination, or discharge of a federal tax lien
• Respond to asset seizures and property sales
• Address passport denial or revocation for seriously delinquent tax debt

State and Local Tax (SALT) Representation

Tax obligations do not end at the federal level. State and local taxing authorities have their own procedures, deadlines, and relief programs — and their collection tools can be just as aggressive as the IRS’s. Our state and local tax attorneys assist with:

• Voluntary disclosure agreements (VDAs) — in many states, a taxpayer who discovers a previously unreported liability can come forward in exchange for a limited lookback period and reduced or waived penalties
• Reasonable cause penalty abatement — available in various forms across many states for income tax, sales and use tax, employment and withholding tax, and other liabilities
• State income tax audits and administrative appeals — negotiating with state departments of revenue and taxation
• Sales and use tax audits — a frequent pain point for retailers, restaurants, contractors, and e-commerce sellers, including economic nexus questions after South Dakota v. Wayfair
• Residency and domicile audits — disputes over which state may tax your income, common for remote workers, retirees, and individuals who split time between states
• Employment and withholding tax disputes, including responsible person liability
• Local and municipal taxes — including local income, business privilege, gross receipts, and property-related taxes, which vary considerably by locality and carry their own filing, payment, and appeal procedures
• State tax payment plans, settlements, and hardship programs — many states offer counterparts to federal installment agreements and offers in compromise

Because state and local tax rules differ significantly from one jurisdiction to the next, we work closely with each client to identify which rules apply and which relief programs may be available.

Tax Planning and Business Tax Counsel

Resolving a tax problem is only half the picture — preventing the next one matters just as much. Working alongside our business, corporate, and M&A practice, we counsel clients on:

• Entity selection and structuring (LLC, S corporation, C corporation, partnership) and the tax consequences of each
• Tax considerations in mergers, acquisitions, and business sales, including asset vs. stock sale treatment
• Nonprofit and tax-exempt organizations — 501(c)(3) applications, compliance, and unrelated business income tax (UBIT) issues, in coordination with our nonprofit law practice
• Employment tax compliance and worker classification, in coordination with our employment law practice
• Tax issues affecting immigrants and foreign nationals, including ITIN matters and residency-based filing obligations, in coordination with our immigration law practice

This page is provided for general informational purposes only and does not constitute legal advice or tax advice. It does not create an attorney-client relationship between Premier Legal Solutions LLC and any reader. The outcome of any legal matter depends on its specific facts and circumstances, and prior results do not guarantee a similar outcome in any future matter. Tax laws, procedures, and relief programs vary by jurisdiction and change over time; nothing on this page should be relied upon as advice for any particular situation. For advice regarding a specific matter, please contact our office to schedule a consultation. Attorney Advertising.