Tax Representation
As a result of the decades of prior government experience members of our firm possess, including employment in the IRS Audit Division, as well as IRS Counsel’s Office, Andreozzi Bluestein LLP is extremely well versed in how to best deal with an IRS audit.
Audit Representation
As a result of the decades of prior government experience members of our firm possess, including employment in the IRS Audit Division, as well as IRS Counsel’s Office, Andreozzi Bluestein LLP is extremely well versed in how to best deal with an IRS audit.
Dealing with tax authorities can be intimidating. If you are currently under audit, owe money to the IRS, or have any other tax related problems, Andreozzi Bluestein LLP is an essential part of the solution to your tax problem.
Our 25 years of experience includes the representation of individuals and businesses at all levels of a tax controversy in matters involving:
Tax Audits and Investigations
Innocent Spouse Litigation
Worker Classification Issues
Corporate Officer Liability and Trust Fund Recovery Penalty Cases
However, this is not true when a corporation owes certain types of taxes to the federal and state tax authorities. If a corporation owes “trust fund taxes” which are taxes it collects on behalf of the government such as employment taxes or sales tax, corporate officers and others in positions of authority face personal exposure. If you are an owner, officer or responsible person for a corporation that owes trust fund taxes to the IRS or New York State, call the attorneys at Andreozzi Bluestein LLP.
IRS Collection Enforcement
It is important to understand that, unlike a collection agency, the IRS or any state taxing authority does not have to file a civil law suit against you in order to obtain a legal judgment; it only has to determine your tax debt, properly notify you, and make an assessment against you. If you won’t or can’t pay the liability or if you refuse to engage in the process, the IRS can file a notice of federal tax lien against your property, levy your bank accounts and wages and legally seize your assets. Similar (but not identical) powers exist for the state taxing authorities to forcibly collect a tax debt.
Ignoring the IRS or the State is just not a solution. Call the attorneys at Andreozzi Bluestein LLP today. We will work with you to develop a real resolution to your tax problem.
IRS Liens
The assessment lien should not be confused with a filing of a Notice of Federal Tax Lien, which is nothing more than a public proclamation of the existence of the assessment lien. However, it is important to note that there are many ways to deal with a Notice of Federal Tax Lien.
First, a taxpayer has a right to appeal the filing of a Notice of Federal Tax Lien within certain time constraints. Second, even if the Notice of Lien is not appealed timely a solution to the Federal Tax Lien may be in the form of a Request for Discharge of Lien, Request for Subordination of the Lien, Request for Withdrawal of the Lien or Request for Release of the Lien. There are many potential solutions to deal with and legally transfer property secured by a Federal Tax Lien. The key to finding the right solution depends on the particular circumstances of your case.
IRS Levy and Request for Collection Due Process Hearing
The ability to request a Collection Due Process Hearing or an Equivalency Hearing can be a powerful tool to control the collection process and propose less intrusive collection alternatives. It can even be used to raise the validity of the underlying liability at the hearing if you did not receive a notice of deficiency for the liability in issue or did not otherwise have an opportunity to dispute the liability. However, timing and strategy decisions come into play depending on the type of tax liability in issue. It is important to contact a law firm that is knowledgeable in tax procedure to analyze your particular situation before valuable Appeal Rights are lost or misused.
Offers In Compromise
At Andreozzi Bluestein LLP, we analyze each individual situation to strategize and determine the best solution for your case. If an offer in compromise is a potential solution to your tax problem, we analyze your particular circumstances to advise you as to both the offer process and the correct amount of your offer. Once determined, we prepare your offer, submit it to the IRS and represent you before the IRS throughout the entire process. However, if you are not a candidate for an offer in compromise, at Andreozzi Bluestein LLP we explain to you why an offer is not the right solution to your tax problem and counsel you as to other potential solutions. Any practitioner can take your money and file an offer in compromise, but how many counsel you on the likelihood of success, and when low, develop an alternate strategy to solve your tax problems? The offer in compromise program is a powerful tool for solving tax problems, but is not the right tool for every taxpayer.
Installment Payment Agreements
We have provided advice and representation to hundreds of businesses and individuals which have saved our clients millions of dollars and provided them with real solutions to their tax problems.
Latest News
A Taxing Initiative: New York State Suspends Driver’s Licenses for Delinquent Tax Debt
By: Gary P. Bluestein and Gregory D. Verdibello The New York State Department of Taxation and Finance (“DTF”) is becoming increasingly aggressive in its methods to collect tax debt from taxpayers. On August 5, 2013, ...
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By Gary Bluestein Sometimes, for a variety of reasons, it is just not possible to settle a case at the examination level. For income, estate or gift tax cases that do not settle at exam, time permitting, the IRS will issue a ...
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By Gary Bluestein Being a tax column, the focus is usually on intricate tax issues of concern to the tax lawyer or perhaps an accountant. However, in the past, I have attempted to make the articles that I have contributed broader ...
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By Gary Bluestein Introduction The issues created by the intersection of bankruptcy law and tax law are exceedingly complex and full of pitfalls for the unwary practitioner. Unfortunately for lawyers practicing in only one of ...
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By Deborah J. Weber A federal tax lien is created when the following three things occur. Assessment Notice and Demand for Payment Non-payment The lien arises on the date of non-payment and relates back to the date of assessment. ...
Read moreDo You Have Unfiled Tax Returns?
By Deborah J. Weber For various reasons, you may not have filed your federal income tax return for this year or previous years. You may not have filed because you expected a refund and you just haven’t taken the time to ...
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By Deborah J. Weber, Esq. Estate Planning and Elder Law Planning… What You Need to Know Estate and Gift Tax Planning Estate and Gift Tax Estates and gifts are taxed using a unified rate schedule. Each person has a credit, ...
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Read moreIRS Innocent Spouse Requests
Relief from Joint Income Tax Liability: Then and Now Deborah J. Weber Although we have grown up with joint returns and joint and several liability, our current tax system existed for five years without joint returns (introduced ...
Read moreWe are a law firm built on Experience, Vision & Trust
Whether you need tax counsel for litigation, representation before the IRS, an advocate in tax controversies, or thorough tax analysis and objective consulting, our attorneys have the experience and obtain lasting solutions.