Individual Tax Controversy & IRS Collections
Individual Tax Controversy Desk
Nineteen named sub-domains covering the arc of a tax dispute — the notice that starts it, the audit, the appeal, the tribunal, and the collection machinery that runs whether or not you are still arguing. The corpus tracks the federal and state tracks separately, because a state assessment follows its own clock and its own doctrine.
Notice Decode, Deadline Triage & Limitations Doctrine
What a given IRS notice actually is, which clock it started, and which deadline on it is jurisdictional rather than merely important.
Examination & AUR Defense
Audit and automated-underreporter practice: what the examiner is entitled to, what substantiation has to look like, and where the record gets made.
Deficiency Ladder & Tax Court Litigation
The path from thirty-day letter to statutory notice to petition — and the door that closes ninety days after the notice is issued.
Appeals Practice
The independent Office of Appeals: hazards-of-litigation settlement, what a protest has to contain, and when Appeals is the better forum than court.
Collection Due Process & Enforcement Defense
Liens and levies, the CDP hearing that suspends them, and the difference between a challenge to the collection and a challenge to the underlying liability.
Collection Alternatives & Financial Analysis
Installment agreements, offers in compromise and currently-not-collectible status, read against the collection financial standards that decide which one is reachable.
Penalty Abatement Doctrine
Reasonable cause, first-time abatement and statutory exceptions — the grounds that actually move a penalty rather than the ones that merely sound sympathetic.
Innocent Spouse & Joint Liability
Relief from a joint return: the three routes, what each requires, and the equitable factors that decide the ones that are not automatic.
State Residency & Domicile Audits
Where a person is taxed as a resident, and the day-count and domicile evidence a state actually weighs when it disagrees.
Refund Claims & Suits
Claiming money back once a tax is paid: the claim, its filing window, and the refund suit if the IRS says no.
Trust Fund Recovery Penalty
Personal liability for a business's unpaid payroll taxes: who counts as responsible, and what willful means.
Bankruptcy Dischargeability
Whether an assessed federal or state tax debt can be discharged in bankruptcy, and the timing tests that decide it.
Civil-to-Criminal Boundary
The signs that a civil audit is heading toward a criminal referral, and how representation changes when it does.
Taxpayer Advocate & Account Remediation
Passport certification, identity-theft returns, and hardship requests that run outside the appeal process.
Federal–State Conformity & Parallel Proceedings
How a federal adjustment becomes a state one, and the duty to report it that can reopen the state's assessment window.
State Assessment, Protest & Tribunal
Contesting a state assessment: the notice, conciliation, the hearing, and review in the state's tax tribunal or courts.
State Collection & Resolution
A state's own collection clocks and tools — warrants, levies, license suspension — and the settlements available.
Nonresident Sourcing & Multistate Double Taxation
How much of a nonresident or remote worker's income a state may tax, and the credits that prevent paying twice.
State Responsible-Person Liability
State rules that make an individual answer for a business's unpaid sales or withholding taxes.