How Our Attorneys Defend You

Challenging “Responsible Person” Status

The IRS must prove you had real control over payroll taxes. We dig into the facts: Who signed the checks, who made the decisions, and who actually handled payroll? The answers to these questions will help us build a case to show you were not responsible under the law.

Contesting “Willfulness”

The penalty only applies if the failure to pay was willful. Maybe you were kept in the dark. Maybe you were following orders. We gather evidence to show you did not intentionally fail to pay trust fund taxes.

Responding to IRS Notices and Appeals

If you receive a proposed TFRP assessment, time is short. We respond quickly, file formal protests, and present your case to the IRS appeals officer. This is your chance to resolve the issue before it becomes final. We know how to deal with IRS offices and revenue officers, and we do it on your behalf.

Negotiating Payment and Relief

If the IRS proves you are responsible, we can still help. We can negotiate an installment agreement, and often times find a way for you to pay less than the full liability.

Litigation in US Tax Court

If we cannot resolve your case in IRS Appeals, we are prepared to proceed to tax court. Our attorneys have represented clients in complex tax litigation, and are always focused on protecting your assets and your future.

Our Process for Protecting You

Step 1: Immediate Case Review and Strategy

We review your role in the business, the timeline of events, and any communications you've already had with the IRS. Based on these facts, we build an initial strategy designed to protect you from the outset. .

Step 2: Building Your Defense

We gather all necessary documentation to construct a strong defense against personal liability. This includes corporate records, financial statements, bank signature cards, payroll records, and any other evidence that supports your position.

Step 3: Resolution and Negotiation

We advocate fiercely on your behalf to prevent the IRS from holding you personally responsible. Whether through the appeals process, settlement negotiations, or litigation if necessary, we pursue every available avenue to protect you. If the IRS does legally deem you a responsible party, we negotiate a resolution for the business's underlying tax debt.