TAX RESOLUTION
Getting a notice from the Internal Revenue Service or from a state revenue department can mean complicated legal problems for your business or for you personally. If you have a tax liability matter that needs resolution, talk to an experienced tax attorney at Celello Law Group.
Is there a tax lien or levy against your personal property or against your business? Have you received tax liability notices? You need to deal with tax problems as quickly as possible while evidence in your defense is fresh and penalties and interest have not begun to escalate.
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Do you have a personal income tax problem? Have you been accused of not declaring all your income or failing to file personal income taxes? Talk to one of our attorneys about your obligations and your options.
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Are your business income taxes in arrears? Is there a question about your sales tax payments? Discuss the tax liability issue with our firm before the problem gets worse.
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Has your business been accused of not remitting employment withholding taxes? Whether or not you are in compliance, you need to settle the tax liability issue as soon as possible.
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Do you need legal advice about an appeal of an IRS or state tax decision? Contact an experienced tax attorney at Celello Law Group.
The firm focuses on resolving your tax problems with the IRS and state tax authorities in a timely manner with your best interest in mind.
- Offers in Compromise
- Installment Agreements
- Penalty Abatement
- Appeals
- Payroll Tax Issues
- Litigation
When you contact us, an attorney licensed in the State of Georgia and admitted to practice before the IRS and United States Tax Court will oversee your case from beginning to end. We will outline the specifics of your case and map out the best solution possible based on your current situation. If you've received any certified mail or other threatening correspondence recently, make sure and tell us so we can take the necessary steps to intervene with immediate action. Don't wait until it's too late! Relief is just a simple phone call or a click away.
Offer in Compromise
This program was developed by Congress to help collect large amounts of outstanding tax in a relatively short period of time. Their assumption was to offer taxpayers a one-time opportunity to eliminate their debt for a fraction of what was originally owed, thus closing millions of costly collection cases. While the program has been and continues to be modified, it remains the most effective means for both taxpayer and IRS to bring about permanent resolution.
An offer in compromise is an agreement between a taxpayer and the IRS that resolves the taxpayer's tax debt. The IRS has the authority to settle, or "compromise," federal tax liabilities by accepting less than full payment under certain circumstances. A tax debt can be legally compromised for one of the following reasons:
- Doubt as to Liability
- Doubt as to Collectability
- Effective Tax Administration
Qualifying for this program should be relatively straightforward: when there is a financial hardship and the amount owed exceeds one’s ability to realistically pay off the debt in five years, the IRS is willing to settle the liability. On average, the qualified taxpayer saves thousands of dollars, and the IRS, in turn, ends its collection process. When you call Celello Law Group we will walk you through the procedure, answering any questions, and providing a free assessment of your case.
Installment Agreements
This program is for taxpayers and businesses who cannot settle their entire tax debt at one time and need to make payments on it. This means valuable time to catch up and escape the harassment and embarrassment of revenue officers and agents, allowing room to map out an affordable solution. If the IRS has burdened you with an unreasonable payment plan or is threatening to levy on your wages, bank accounts and other assets, we can get you a payment plan that conforms to your current financial requirements or, if your financial condition warrants, we can have your account placed in a “not currently collectible” status. Under this program, the IRS withholds all collection activity until you are financially able to accept a payment plan or have an Offer in Compromise submitted. When you call, we will explain the specifics of this program, outlining a realistic proposal to meet your financial goals.
Penalty Abatement
Besides the Offer in Compromise, there is another, very effective program for reduction of an outstanding tax debt. If there were circumstances beyond your control that prevented you from paying your tax debt and led to delinquency, we can challenge the penalties that have built up and negotiate them down. Relief from penalties falls into four separate categories. They are:
- Reasonable Cause – Mistake made by the taxpayer, ignorance of law, death, serious illness, unavoidable absence;
- Statutory Exceptions–Simple or complex legislative tax code changes;
- Administrative Waivers – Undue hardship, fire, flood, natural disaster, bad legal/tax advice; and
- Correction of Service Error – Mistake made by the IRS.
This program involves a great deal of skill to successfully navigate the IRS protocol and bring resolution. If applied for correctly and effectively, results are substantial; savings are usually thousands of dollars for the average taxpayer. We will meet with you to discuss if you would be a candidate for this relief.
Appeals
Keep in mind that the IRS is very aggressive in its collection attempts for past due payroll taxes. The penalties assessed on delinquent payroll tax deposits or filings can dramatically increase the total amount owing in a matter of months.
Not only is your business at risk--you may be personally liable, as well. Once the IRS has determined the business cannot pay its past due payroll taxes, the IRS then turns its sights on the individuals it deems responsible.
We have helped business owners resolve their tax issues with great success. If you meet the qualifying criteria, Celello Law Group can design for you a game plan for repayment of taxes and negotiate with the IRS to avoid bank levies and asset seizure.
Payroll Taxes
If you do not agree with the results of an IRS decision on your case, you can appeal your case to a local IRS Appeals Office. You must timely submit your request for an appeal on you case. You or your representative must be prepared to discuss and argue all disputed issues with the appeals officer. In most instances, if agreement is not reached at your appeals conference, you can take your case to Tax Court and have a judge review your case.
A timely written protest is required which sets forth information to support your position. You must also file a written protest if your case involves reconsideration of liens, levies, seizures, or installment agreements.
It is generally recommended that you retain an attorney to represent you in the appeals process because of the maximum protection of attorney-client privilege that is only available when an attorney represents you can represent you and ensure that your interests are protected.
Litigation
Sometimes your case cannot be resolved through negotiation with the IRS or state tax authority. The attorneys at Celello Law Group are licensed in the State of Georgia and admitted to the U.S. Tax Court and U.S. District Court and can help you resolve your matter through litigation.
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