LTL provides clients with advice, counsel and representation in audits and collection activities.
A tax audit is a disputed matter between a taxpayer and tax authority, such as the IRS. Tax audits can be specific to businesses, individuals, estates and trusts and can be at the state, federal or foreign tax level. LTL helps clients with tax audits relating to income tax, estate and gift tax matters. We protect the interests of our clients while working to resolve their tax audits, whether at the federal or state level.
The following is a partial list of related matters in which LTL regularly represents our clients:
- Audit assistance: LTL provides legal counsel, helping our clients prepare for an audit.
- Audit appeals: We can appeal an audit to the IRS Appeals Office or the State Board of Equalization (BOE). If necessary, we can take a taxpayer’s case to the United States Tax Court or other appropriate court. Audits can be challenged on either a legal or factual basis. We analyze each case to determine if the agent misinterpreted the actual facts or the law.
- Tax penalty abatements: Taxpayers may qualify for relief from penalties for failing to file tax returns or not having their returns prepared properly. Tax penalties mount quickly and can easily account for up to 25%-75% of what a taxpayer may owe the IRS. In appropriate cases, LTL can help reduce or eliminate these tax penalties.
- Innocent spouse relief: Many married taxpayers file joint tax returns because of the benefits this provides, but it also means that each partner is jointly and independently responsible for the entire tax liability—even if one spouse earned the money and claimed improper deductions and credits. Innocent spouse relief provides relief from an unpaid tax if a spouse or former spouse failed to report income, reported income improperly or claimed improper deductions or credits. LTL helps spouses evaluate their situations and request relief from joint and independent liability from taxes, penalties and interest due from a jointly filed return, if appropriate.
- Installment agreement negotiations: Taxpayers can structure a monthly payment plan if they cannot pay the amount they owe in current taxes, back taxes and penalties. The installment agreement is based on the taxpayer’s current financial situation. LTL negotiates with the IRS on behalf of our clients to structure tax-installment agreements.
- Offers in compromise: An offer in compromise is an agreement between the taxpayer and IRS that settles the taxpayer’s tax liabilities for less than the full amount owed. It helps taxpayers reduce their tax debt based on their financial situations or other legal circumstances. This may be a legitimate option if a taxpayer is unable to pay his/her full tax liability, or if doing so creates a hardship, based on income, assets and expenses. LTL works on behalf of our clients to compromise tax settlements in appropriate cases.
- Payroll tax liabilities and penalties: Businesses that do not submit payroll taxes on time are subject to penalties; the assessed rates escalate with the number of days the taxes are delinquent. Sometimes, penalties for payroll tax liabilities may be abated. LTL represents our clients in these cases to reduce payroll tax penalties.
- Refunds and refund litigation: In tax cases where clients believe they have not received appropriate refunds, LTL helps them facilitate the refunds or other appropriate legal actions to obtain the refunds.
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