Let our Tax Collection attorneys represent you before the Collection Division of the Internal Revenue Service and the state taxing agencies. Because of our vast knowledge and experience representing taxpayers in collections, we can quickly resolve enforced collection matters and determine the best avenue for relief.

Our area of expertise spans the entire collection process and include:

• Representing Non-Filers and Non-Filer Enforcement, challenging Substitute for Returns (SFR) prepared in accordance with IRC section 6020 and representing criminal Non-Filers

• Responding to Delinquent Tax Notices involving Service Campuses, ACS, and Field Group Revenue Officers

• Statute of Limitations for Collection Issues

• Tax Liens – Place of Filing Determinations, Release of Erroneous Liens, Collection Due Process Hearings, Super Priorities Interests, Application of the 45 Day Rule, Release, Discharge and Subordination of tax liens, Lien Subrogation Requests and Applications for Certificate of NonAttachments

• Spousal Rights and Community Property Issues

• Seizure and/or Sale of Assets – including challenges to Writs of Entry, Trade or Business Seizures, No Equity Seizures, Residential Seizures and Release of Seized Property

• Notice of Levy, Obtaining a Release of Levy and Levy Appeal Rights (Bank Accounts and Wages) and Wrongful Levies

• Summonses – Taxpayer and Third-Party Summonses including Defenses and Motions to Quash

• Payment Agreements and proper completion of IRS Collection Forms (433-A, 433-B and 433-F)

• Offers In Compromise

• Judicial Relief from Collection Action (Civil Damages, Failure to Release Lien)

• Taxpayer Assistance Orders and Taxpayer Advocate Actions

• Currently Not Collectible Accounts (“53ing Account”)

• Application and Direction of Payments Strategies

• Fraudulent Conveyances and Nominee Liens

• IRS Record System Requests – securing documents, IRS Computer System and Master Files, Service Center Requests and Integrated Data Retrieval System (IDRS) Tax Transcripts Requests

• Criminal Enforcement

• IRS Passport Denial or Revocation Representation – Tax Workout Group specializes in enforced collection defense representation, including IRS passport revocation. Our team will work expeditiously toward preserving your passport rights, restoring your ability to travel freely in several ways, including negotiating installment agreements, preparing and filing an Offer-In-Compromise, disputing the underlying tax claims and related penalties, and filing a tax bankruptcy.