Release of IRS Bank Levy for Corporate Taxpayer Facing Over $550,000 in Payroll Tax Liability
Jack Naranjo
Results
How IRS Bank Levies Affect Businesses With Payroll Tax Debt When federal tax liabilities remain unpaid, the IRS may take enforcement action to collect the outstanding balance. One of the most severe collection tools is a bank levy, which allows the IRS to seize funds directly from a business bank account. For businesses, a bank levy can immediately...
Representation of Buyer in $6 Million Multistate Logistics Company Acquisition
Richard James
Results
Structuring Business Acquisitions for Tax Efficiency and Multistate Operations Business acquisitions often involve complex legal and tax considerations, especially when the target company operates across multiple states. Buyers must evaluate transaction structure, financing, tax consequences, and regulatory compliance to ensure the deal aligns with...
Successful Completion of Four-Year Estate Administration Involving Business Debt and Real Estate Holdings
Richard James
Results
How Estate Administration Works in Complex Probate Cases Estate administration is the legal process of settling a deceased person’s financial affairs through probate court. This process includes identifying and managing assets, resolving outstanding debts, addressing creditor claims, and distributing property to beneficiaries. When an estate includ...
Successful Defense of IRS NRP Audit for Client with Multiple Businesses
Jack Naranjo
Results
What Is an IRS National Research Program Audit and How It Works When the IRS National Research Program, or NRP, is a type of audit designed to collect data about taxpayer compliance. Unlike standard audits that are triggered by specific issues, NRP audits are often randomly selected and used to improve IRS enforcement models. Despite their research...
Successfully Lifted IRS Bank Levy for Nonprofit Religious Client
Jack Naranjo
Results
How IRS Bank Levies Impact Nonprofits and Religious Organizations When federal tax liabilities remain unpaid, the IRS may take enforcement action to collect the balance. One of the most disruptive tools is a bank levy, which allows the IRS to seize funds directly from a taxpayer’s bank account. For nonprofit and religious organizations, a bank levy...
Texas Comptroller Sales Tax Audit Liability Reduced by $107,000
Julia Salzman
Results
How Texas Sales Tax Audits Create Additional Tax and Penalty Exposure Businesses operating in Texas must comply with sales and use tax requirements enforced by the Texas Comptroller. When discrepancies are identified during an audit, the state may assess additional tax, interest, and penalties based on its review of the company’s records. Sales tax...
Recovery of Nearly $2.3 Million Refund Through CARES Act NOL Carryback Representation
Jack Naranjo
Results
How CARES Act NOL Carryback Rules Created Refund Opportunities The CARES Act introduced temporary changes to net operating loss rules, allowing taxpayers to carry back losses from 2018 through 2020 for up to five years. This provision allowed businesses and individuals to offset prior taxable income and claim refunds for taxes paid in earlier years...
The Wilson Firm Saved $1.1 Million in Worker Reclassification Audit Case
Blog Manager
Results
IRS Worker Classification Audits and Payroll Tax Risk for Businesses Businesses that rely on independent contractors may face IRS scrutiny over whether those workers should be classified as employees. Worker classification directly affects payroll tax obligations, including federal income tax withholding, Social Security, and Medicare taxes. If the...
IRS Eases Penalty Assessment Rules for Late-Filed Foreign Gift and Inheritance Forms
Blog Manager
Results
IRS Ends Automatic Penalties for Late Form 3520 Filings The IRS recently implemented an important change affecting taxpayers required to report foreign gifts, inheritances, and certain foreign trust transactions using Form 3520. Previously, when taxpayers filed Form 3520 late, the IRS automatically assessed penalties even when a reasonable cause ex...
Trust Domestication and Strategic Elimination of California Tax Nexus for High-Net-Worth Client
Richard James
Results
How Trust Structures Can Create California Tax Nexus State tax laws can significantly impact how trust income and investment earnings are taxed. A trust or related entities may create a state tax nexus, which allows a state to impose tax on income even when assets or beneficiaries are located elsewhere. California applies complex rules to the taxat...
Withholding Issue Resolved — Tax Assessment Reduced from $86,000 to $650
Julia Salzman
Results
How IRS Tax Assessments Arise From Withholding Errors Taxpayers receive credit for federal income taxes withheld from wages as reported on Form W-2. When the IRS cannot verify withholding or believes it was not properly reported, it may issue a notice proposing additional tax based on its internal records. In some cases, discrepancies between emplo...
Creation of Family Limited Partnership for High-Net-Worth Real Estate Portfolio
Richard James
Results
How a Family Limited Partnership Supports Real Estate and Estate Planning Real estate investors with substantial property holdings often face complex issues involving liability exposure, tax efficiency, and long-term asset management. Without a structured ownership framework, investors may be exposed to unnecessary legal risk and limited flexibilit...
Individual’s IRS Wage Levy Removed After Negotiated Resolution
Jack Naranjo
Results
How IRS Wage Levies Work and Impact Taxpayers When federal income tax liabilities remain unpaid, the IRS may take enforcement action to collect the outstanding balance. One of the most aggressive collection tools is a wage levy, which allows the IRS to garnish wages directly from a taxpayer’s employer. An IRS wage levy can result in a significant p...
Choosing the Right Path: DIIRSP vs. Streamlined Domestic Offshore Procedures
Julia Salzman
IRS Collection Matters
IRS Offshore Compliance Options for Foreign Asset Reporting Many tax practitioners and taxpayers have noticed increased enforcement in the international tax space. It’s always better to correct failures in filing foreign information returns or FBARs before receiving a letter from the IRS. In certain situations, taxpayers who are living in the Unite...
Successful DOJ Negotiation to Avoid Criminal FBAR Prosecution and Reduce Penalties by 69%
Blog Manager
Results
FBAR Reporting Requirements and Risk of Civil and Criminal Penalties U.S. taxpayers with financial interests in foreign bank accounts or offshore entities may be required to file Foreign Bank Account Reports, known as FBARs, with the U.S. Treasury Department. These reporting requirements apply when the total value of foreign accounts exceeds certai...
$134,000 Fraud Penalty Reduction Secured Through Texas Sales Tax Audit Redetermination
Julia Salzman
Results
Fraud Penalties in Sales Tax Audits and How They Are Challenged Sales tax audits conducted by state taxing authorities can result in additional tax assessments, interest, and penalties when discrepancies are identified. In certain cases, the taxing authority may assert fraud penalties, which significantly increase the total liability. Fraud penalti...
Successful Offer in Compromise Appeal Results in Over 90% Reduction in Liability
Julia Salzman
Results
How an Offer in Compromise Can Reduce IRS Tax Debt An Offer in Compromise, or OIC, is an IRS program that allows qualifying taxpayers to settle their tax debt for less than the full amount owed. This option is available when paying the full liability would create financial hardship or when the taxpayer’s financial situation limits their ability to ...
Appeal Success: Trust Fund Recovery Penalty Avoided, Saving Client $171,000
Julia Salzman
Results
What Is a Trust Fund Recovery Penalty and Who Can Be Held Liable A Trust Fund Recovery Penalty, or TFRP, may be assessed by the IRS when employment taxes withheld from employees are not properly remitted to the government. These taxes are considered trust fund taxes because they are collected from employees and held by the employer for payment to t...
Sales Tax Audit Appeal Results in $70,000 Penalty Reduction
Julia Salzman
Results
How Texas Sales Tax Audits Lead to Penalties and Assessments State tax authorities regularly conduct sales tax audits to verify that businesses are properly collecting, reporting, and remitting sales tax. When discrepancies are identified, the taxing authority may assess additional tax, interest, and penalties. Penalties imposed during a sales tax ...
Strategic Victory: The Wilson Firm's Expert Negotiation Reduces ESRP Penalty from $465,000 to $9,000
Blog Manager
Results
Understanding ESRP Penalties Under the Affordable Care Act The Employer Shared Responsibility Payment, or ESRP, is a penalty imposed under the Affordable Care Act on certain employers that fail to meet health coverage requirements for their employees. These penalties are governed by Internal Revenue Code Section 4980H. There are two primary types o...

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