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(212) 588-1113
(212) 588-1115
(888) 712-7690

for all IRS tax issues,
problems & emergencies.

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:: ab@irstaxattorney.com

 

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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.

 

CPAs, accountants, bookkeepers, enrolled agents, and attorneys without a tax specialty may not have the time, experience, education, insight or technical skill to deal with the technical analysis, legal research, identification of issues, interpretative creativity and insight, negotiating skills, knowledge of the IRS , or technical writing ability necessary to effectively prevent avoidable tax overpayments.

 

more info

 

 

:: TAX INFORMATION

- Selecting a Tax Attorney

- 10 Things to know about OICs

:: ARTICLES BY ALVIN BROWN

- Corporation Levies
- Levies
- Liens
- Offer in Compromise
- Offer in Compromise - Levy Abuse

- More Articles by Alvin Brown...

:: RECENT TESTIMONIES

- Testimonies

 

:: DOWNLOAD IRS FORMS

- Form 656

- Power of Attorney Form 2848

 

:: SECTION 6694 PENALTY

- Section 6694 Penalty Site

:: 6694 PENALTY ARTICLES

- 6694 Article I
- 6694 Article II
- 6694 Article III

:: YOUTUBE VIDEO SERIES

- Offer in Compromise
- Back Taxes
- Statute of Limitations
- Tax Liens
- Tax Levies
- Tax Fraud & Criminal Investigations
- Section 6694 Penalty
- Installment Agreements
- Penalty and Interest Abatement
- Trust Fund Penalties & Payroll Taxes
- Tax Attorney Representation
- Offer in Compromise / No Liability
- OIC / Effective Tax Administration
- IRS Collections
- IRS Forum
- Employee/Subcontractor
Classification Issues

- Taxpayer Advocate
- OIC / Special Issues
- OIC / Financial Analysis
- OIC / Legislative History
- Hobby Losses
- Power of Attorney

 

 

 

:: ARCHIVED RESOURCES

Tax Preparation
Offer In Compromise
Levy
IRS Tax Liens
IRS Tax Liens - continued
IRS Tax Liens - continued 2
Levy - continued
IRS Audits
Audit Techniques Guide
Congressional Contacts
Criminal Investigation
D.O.J Criminal Tax Manual
Tax Litigation
Penalty
Installment Agreements
Statute of Limitations
Frivolous Tax Argument
Interest Abatement
Tax Fraud
Fraud Statutes
Bankruptcy
Tax Reform Legislation
Tax Shelters
Tax Court
Trust Fund Penalty
Legislation
Innocent Spouse Relief
Important Links

 

 

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Presented by Alvin Brown and Associates, tax attorney, formerly with the Office of the Chief Counsel of the IRS.
Call us for all IRS tax issues, problems and emergencies.
www.irstaxattorney.com - ab@irstaxattorney.com - (888) 712-7690 - (877) IRS-1172