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TAX HELP
:: IRS Tax Attorney TAX HELP
Alvin Brown and Associates is a tax law
firm representing taxpayers throughout the U.S. and abroad
before the IRS. IRS representation is the specialty of our
tax law firm. Our representation includes civil and criminal
examinations, collection issues, tax settlements, tax liens,
tax abatements, advisory opinions and similar matters
involving representation and interaction with the Internal
Revenue Service.
We are “advocates” in our
representation of taxpayers before the IRS. In that
advocacy we use legal memoranda, as needed, to support our
advocacy based on the Internal Revenue Code, tax
regulations, IRS administrative manuals, published IRS
positions, the tax legislative history to support our oral
advocacy. It is very important to support a taxpayer
position for the administrative record given the review of
tax matters by managers, reviewers, other management, and
the IRS Office of Appeals. Some tax issues depend on State
law, and we research and use State law as needed. We use a
have a daily tax service for new case law and current
legislative changes as they occur. Our specialized IRS tax
practice is comprehensive.
We also give advice and assist
accountants, CPA, enrolled agents and other attorneys who do
not have our technical expertise and insight into IRS
practices, procedures.
We respect the law that
Congress writes and one of our primary goals to make sure
that the IRS makes its determinations with “integrity” and
“fairness.” Unfortunately, the IRS is not always fair in
the exercise of its discretion, its determinations on
factual issues and its application of the tax law. For that
reason we extend ourselves in our representations to be
equally aggressive if necessary.
It is very difficult to help
any taxpayer unless they are in compliance in filing their
tax returns. W-2 employees must file all tax returns
annually, and Form 1099 employees must file quarterly
self-employment tax returns. All tax returns are an
affidavit signed under penalties of perjury. Therefore, it
is critical that tax returns be prepared in good faith and
at the highest level of accuracy.
We will assist taxpayers who
have not filed tax returns with tax return preparation. Tax
returns that are not filed put taxpayers at an enormous
disadvantage because:
1) The statute of limitations will not commence.
2) There will be a non-filing penalty.
3) A negligence penalty.
4) Interest compounded daily.
If
information is incomplete tax returns should nevertheless be
filed with full disclosure on any information that is
incomplete or undocumented as long as the filing is not
frivolous. We assist taxpayers who have incomplete data,
lost records, or other filing problems. It is imperative
that tax returns be filed timely notwithstanding current
filing issues. All unfilled tax returns must be filed.
The IRS will not accept an Offer in Compromise to reduce a
tax debt unless all tax returns are filed. An Installment
Agreement is available for those who may not qualify for an
Offer in Compromise.
Tax returns may be filed even
if the IRS filed a tax return under its authority to prepare
tax returns for those who have not filed tax returns. We
assist with amended tax returns and challenges to a tax
liability that may be challenged, including the trust fund
recovery penalty.
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