Innocent Spouse
Innocent Spouse Relief — Divorced Taxpayer
Haddonfield woman held liable for $135,000 in taxes from ex-husband's unreported income. We obtained full innocent spouse relief.
Owed
$135,000
Paid
$0
Saved
100% relief
When The IRS Won't Stop
Additional Tax Services
Specialty tax matters — bankruptcy, foreign accounts, estate planning, payroll, gambling, and more.
30+ Years In The Trenches
Real Lawyers — Not A Call Center
A+ BBB · Thousands Resolved
§108
Insolvency exclusion we apply weekly
3-2-240
Bankruptcy discharge rules we navigate
30+ yrs
Handling specialty tax matters
Kovel
Accountant privilege from day one
What's actually happening
Tax debt isn't a number on a letter. It's compounding daily — and the IRS has weapons.
Tax law touches almost every part of a financial life — and some of the highest-stakes matters don't fit neatly into 'collections' or 'audit defense.' A Chapter 7 filing can wipe out a six-figure IRS debt, but only if every one of the three timing rules is satisfied. An unreported foreign account can be cured through the Streamlined Disclosure Procedures — or, filed wrong, can become a willful FBAR penalty larger than the account itself. A cancellation-of-debt 1099-C after a foreclosure can be excluded under §108 insolvency, but only with the right Form 982 election. Payroll trust-fund recovery penalties are personal liability that survives the corporation. These matters demand a tax attorney who has done each of them many times. We have.
Specialty matters we handle
When the case doesn't fit a category, it still needs a tax attorney.
11 U.S.C. §§ 523, 507
Discharge IRS debt in bankruptcy
Older income taxes can be wiped out in Chapter 7 — but only if the 3-year, 2-year, and 240-day rules all align. We analyze every dollar before filing.
How we handle itFBAR + FATCA
Foreign bank account compliance
Streamlined Disclosure, Delinquent FBAR Submission, or Voluntary Disclosure — the right program depends on willfulness. The wrong one is catastrophic.
How we handle itIRC § 6672 TFRP
Trust-fund recovery penalties
The IRS pierces the corporate veil to collect unpaid payroll taxes personally. We fight responsibility and willfulness on the Form 4180 interview.
How we handle itPre-collection planning
Estate and asset-protection planning
Done before assessment, legitimate planning is allowed. Done after, it's a fraudulent transfer. Timing is everything.
How we handle it§108 / Form 982
Cancellation-of-debt income after foreclosure
A 1099-C looks like phantom taxable income — but the §108 insolvency exclusion erases it when properly elected.
How we handle itPre-criminal-referral
Getting current on unfiled returns
Unfiled returns are the #1 trigger for criminal referral. We file the right years in the right order to shut the case before it starts.
How we handle itHow we work
A real process. Real timelines. No vague promises.
- 01
Free, attorney-client privileged scoping call
These matters are fact-specific. We listen, identify the controlling statute, and tell you the cost and timeline within the first conversation.
- 02
Document and transcript review
FBAR cases need 8 years of account statements. Bankruptcy cases need every IRS account transcript. We pull what we need before quoting a strategy.
- 03
Program / vehicle selection
Streamlined vs. Delinquent vs. Voluntary Disclosure. Chapter 7 vs. Chapter 13. Trust-fund hearing vs. settlement. Each path has a different exposure profile — we model both before recommending.
- 04
Quiet, technical execution
These cases reward precision over noise. We file what is required, exactly when required, and no more — keeping IRS attention narrow.
- 05
Close-out and forward planning
We confirm the discharge, the FBAR acceptance, or the TFRP abatement is posted — then build a compliance plan that prevents recurrence.
Every service in this category
Whatever the IRS is doing — there's a legal tool to stop it.
Fresh Start Initiative
Take advantage of IRS programs designed to help taxpayers get a clean slate.
Read morePayroll Tax Problems
Resolve trust fund recovery penalties and payroll tax delinquencies.
Read moreTrust Fund Recovery Penalty (TFRP) Defense
Personal-liability defense under IRC § 6672 against responsible-person assessments for unpaid payroll trust-fund taxes.
Read moreDelinquent Tax Filings
Get caught up on unfiled tax returns and back into IRS compliance.
Read moreTaxes & Bankruptcy
Determine if your tax debt qualifies for discharge in bankruptcy proceedings.
Read moreBack Taxes Solutions
Comprehensive strategies for resolving years of unpaid back taxes.
Read moreForeign Bank Account Reporting (FBAR)
Compliance with FBAR requirements and voluntary disclosure for unreported accounts.
Read moreOffshore & Foreign Bank Accounts
Navigate offshore compliance programs and resolve foreign account issues.
Read moreEstate Planning & Asset Protection
Protect your assets from IRS collection through legal planning strategies.
Read moreBusiness Tax Planning
Strategic tax planning for businesses to minimize liability and maximize compliance.
Read moreMortgage Foreclosure & Cancellation of Debt
Address tax consequences of foreclosure and canceled debt income.
Read moreTaxation of Gambling Winnings
Proper reporting and resolution of gambling income tax issues.
Read moreIf you got a letter
IRS notices that lead here
The notices below are the most common entry points into a case like this. Tap any one for a plain-English breakdown of what it means and what to do next.
Notice CP14
Balance Due Notice
This is the IRS's first notice telling you that you owe taxes. It shows the amount due, including any penalties and interest.
Notice CP504
Intent to Levy Notice
This is a final notice before the IRS seizes your assets. They intend to levy (take) your state tax refund and may seize other assets.
Notice CP59
Unfiled Tax Return Notice
The IRS has no record of your federal tax return for a prior year and is asking you to file it. CP59 is the IRS's first formal step toward filing a Substitute for Return (SFR) on your behalf — which almost always overstates what you owe.
Notice LT11 / Letter 1058
Final Notice of Intent to Levy
This is the absolute final warning. The IRS will begin seizing your wages, bank accounts, and property within 30 days.
Forms you may need to file
IRS forms tied to this category
Each form has its own page with step-by-step instructions and the mistakes that get returns rejected.
Form 433-A
Collection Information Statement for Wage Earners and Self-Employed
Detailed financial disclosure the IRS uses to decide what you can pay — required for most large installment agreements and Offers in Compromise.
Form 433-F
Collection Information Statement (Short Form)
Shorter financial disclosure used by the IRS Automated Collection System for moderate balances.
Form 1040-X
Amended U.S. Individual Income Tax Return
Used to correct errors on a previously filed Form 1040 — claim missed deductions, fix income, or respond to an IRS adjustment.
Form 2848
Power of Attorney and Declaration of Representative
Authorizes a licensed attorney, CPA, or enrolled agent to represent you before the IRS — speak, sign, and negotiate on your behalf.
Form 8821
Tax Information Authorization
Authorizes a third party (lender, accountant, attorney) to receive and inspect your IRS tax information — without representation rights.
Real outcomes
Recent results in this category
Payroll Tax
Trust Fund Recovery Penalty — S-Corp Owner
Bucks County contractor personally assessed $215,000 in TFRP under IRC § 6672. We challenged the responsible-party determination and prevailed.
Owed
$215,000
Paid
$0
Saved
Personal liability eliminated
Foreign Accounts
FBAR Voluntary Disclosure — Dual Citizen
Princeton dual citizen with 12 years of unreported foreign accounts. We guided streamlined disclosure with non-willful certification.
Owed
Potential $250K+ penalties
Paid
$8,400 tax + minor penalty
Saved
Criminal exposure eliminated
Speak the language
Terms you'll hear in this process
- CSED
Collection Statute Expiration Date — the date after which the IRS can no longer legally collect a tax debt. Generally 10 years from the date of assessment.
- FBAR
Foreign Bank Account Report (FinCEN Form 114) — a report required for U.S. persons with financial interest in or signature authority over foreign financial accounts exceeding $10,000 in aggregate value.
- FATCA
Foreign Account Tax Compliance Act — federal law requiring U.S. taxpayers to report foreign financial assets exceeding certain thresholds and requiring foreign financial institutions to report accounts held by U.S. persons.
- OIC
Offer in Compromise — an agreement between a taxpayer and the IRS that settles a tax liability for less than the full amount owed. The IRS considers the taxpayer's ability to pay, income, expenses, and asset equity.
- POA
Power of Attorney — authorization for a tax professional to represent a taxpayer before the IRS, typically granted via IRS Form 2848.
- SFR
Substitute for Return — a tax return the IRS files on behalf of a taxpayer who has not filed. SFRs typically do not include deductions or credits the taxpayer may be entitled to.
From the journal
Recent writing on this topic
Tax Debt
What Should I Do if I Can't Afford to Pay the IRS?Opening a tax bill from the federal government that you cannot afford to pay is a stressful experience. Learn your options for IRS tax debt relief.
Tax Debt
What Should I Do If I Owe the IRS More Than $10,000?Discovering you owe the federal government a significant amount of money can be overwhelming. Here's what to do if you owe the IRS more than $10,000.
Tax Resolution
How Can I Reduce My IRS Tax Debt Legally?Facing overwhelming IRS tax debt can feel like drowning in quicksand. Learn the legal strategies to reduce what you owe.
Criminal Tax Issues
When the government wants to put you in a cage — we put ourselves between you and them.
ExploreTax Resolution Services
The IRS has lawyers. So should you.
ExploreIRS Collections Defense
When the IRS stops asking and starts taking — there's a legal counter to every move.
ExploreAll services
Browse every service we offer — criminal defense, tax resolution, audit, appeals, planning — in one place.
Service indexEvery Day You Wait, It Gets Worse
Don't Face The IRS Alone. Nobody Should.
Penalties compound daily. Interest doesn't sleep. One call — free, confidential, attorney-client privileged — and you'll finally know exactly where you stand.
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