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A legal memorandum written by an experienced Tax Attorney should accompany any Offer in Compromise submitted to the Internal Revenue Service in order to forcefully present the taxpayer's case to the IRS, put the IRS on notice that the taxpayer has strong representation (a good Tax Attorney representing him or her), and avoid any misapplication of the law and/or abuse of discretion. Penalty Abatement - a simple reduction on the penalty added to the tax and interest you owe. I have had great success in this area because of the technique I use. Areas of Practice Accounting Law
Tax Planning & Consulting - quarterly, annually, specific transactions - tax planning is very important in order to minimize your tax burden. Paying taxes is a responsibility, paying too much tax is a mistake.
Tax Audits - don't go up against the IRS alone, an experienced representative will save you money and prevent future audits.
Offer in Compromise - an agreement between a taxpayer and the IRS that resolves the taxpayer's tax debt. The IRS has the authority to settle, or "compromise," federal tax liabilities by accepting less than full payment under certain circumstances. A tax debt can be legally compromised for one of the following reasons:
Doubt as to Liability - Doubt exists that the assessed tax is correct.
Doubt as to Collectibility - Doubt exists that you could ever pay the full amount of tax owed.
Effective Tax Administration - There is no doubt the tax is correct, and no doubt that the amount owed could be collected, but an exceptional circumstance exists that allows the IRS to consider a taxpayer's OIC. To be eligible for a compromise on this basis, the taxpayer must demonstrate that collection of the tax would create an economic hardship or would be unfair and inequitable.
Taxpayers should beware of promoters' claims that tax debts can be settled for "pennies on the dollar" through the Offer in Compromise Program. Check the OIC requirements to see if an offer in compromise is right for you.
IRS levied bank accounts - a legal seizure (taking) of your property to satisfy a tax debt. The IRS must follow procedural requirement prior to and after seizure of assets. I can help get your property back in most cases.
IRS garnished paycheck – a levy (seizure of assets) in the form of a percentage deduction from your paycheck. I can arrange with the IRS to have wage garnishments stop almost immediately.
IRS levied money from my customers – If your customers owe you money, such as in the form of accounts payable, the IRS will possibly attempt to levy money from your customers. This can have a very detrimental effect on your relationship with your customers and clients. Don’t let this happen to your business, work with me to keep your business operating properly.
Past Due / Unfiled tax returns – I have many years of tax preparation experience at some of the finest CPA firms in the country (unlike most tax attorneys). I can prepare any and all types of unprepared and unfiled tax returns to get you back in compliance.
IRS, State, Agency Audits – I have handled literally hundreds of audits for clients over the years, I know the process, I know what the IRS is looking for, and I know how to work with the IRS to fill in any missing pieces. Let my experience in this area go to work for you.
Installment Agreements – agreement to pay your liabilities over time. Representation is required in this area to ensure the lowest possible monthly payment. Don’t try to negotiate this issue with the IRS yourself. The IRS has professional tax collectors working in this area, you need a professional on your side to even the playing field.
Tax Liens – a legal claim to property as security or payment for past due tax debt. The IRS files hundreds of Federal Tax Liens every day. Procedures must be followed by the IRS to be in compliance with the law. This public notification of tax debt takes priority of almost all other liens and is used by courts to establish priority of claims to real estate and other assets.
Audit Reconsideration - if you've been assessed additional tax, I can possibly have the assessment reversed if the IRS, state taxing agency, you, your prior accountant, or your prior attorney made a mistake.
Tax Deductions
Estate Planning
Entity Planning - formation of corporations and / or partnerships is an effective method of achieving a desired result in many circumstances.
Bankruptcy
Spouse (or ex-spouse or boyfriend) is in trouble – Innocent Spouse Relief is your opportunity to get relief from the tax liability you should not be legally responsible for.
Corporate Counsel - I represent many companies as In-House Counsel in order to address a variety of legal, tax, and accounting needs.
The Law Offices of Michael Fiscus, located in the
Ad Valorem Tax
Criminal Taxation
Criminal Tax Audits
Employment Tax
Estate and Gift Taxation
Excise Tax
Expatriate Tax
Federal Estate and Gift Taxation
Federal Income Tax
Federal Tax Controversies
Federal Taxation
Fiduciary Income Tax
Fiscal Law
Generation Skipping Tax
Historic Rehabilitation Tax Credits
Income Tax
Individual Taxation
Inheritance Tax
International Income Tax
International Tax Controversies
International Taxation
Interstate Tax
Like Kind Exchanges
Local Taxation
Low Income Housing Tax Credits
Low Income Tax Credits
New Markets Tax Credits
Personal Property Taxation
Property Tax
Property Tax Abatement
Property Tax Appeals
Property Tax Assessments
Sales and Use Tax
State Income Tax
State Tax Controversies
State Taxation
Tax Appeals
Tax Audits
Tax Certiorari
Tax Collection
Tax Controversies
Tax Credits
Tax Deferred Exchanges
Tax Evasion
Tax Fraud
Tax Incentives
Tax Law
Tax Legislation
Tax Litigation
Tax Planning
Tax Shelters
Tax Valuation
Taxation of Foreign Nationals
Transfer Tax
Trusts and Estates Taxation
Technology
I use the latest advanced technology in my practice including advanced tax and research software, internet resources, high end equipment, electronic storage of documents, extensive use of e-mail and scanned documents, conference call, video conferencing, remote computer access, multiple monitors, and outsourcing (but within the United States - I am against sending jobs overseas in most cases).
These and other tools help me to be more efficient and keep my costs down which I am able pass along to my clients in the form of lower fees and expenses.
