Individual Tax Controversy

Individuals face numerous challenges and concerns when interacting with the IRS or state tax agencies. These complicated processes include:

  • Handling an audit, appeal, or litigation | Audit Details
  • Resolving past tax debts | Audit Details
  • Submitting unfiled returns
  • Disclosing previously undisclosed foreign assets
  • Tax Liens and Levies
  • Understanding and responding to official notices

The attorneys at Anderson & Jahde have extensive experience in helping taxpayers unburden themselves using efficient, ethical, and equitable approaches. Facing these agencies alone can often result in additional action or bring to life other precarious situations. Utilizing the professional tax attorneys at Anderson & Jahde will help you avoid missteps or potentially costly mistakes. Contact us today to schedule a time with our experts.

Unfiled Tax Returns

Sometimes, not filing a tax return is a Federal crime. This is more likely where tax returns for several years, had they been filed, would have reported substantial taxes owing. Making the wrong moves to get back on track can sometimes make matters worse. Deciding the proper course of action varies with each situation and should not be undertaken by consulting anyone other than an experienced tax attorney like those at Anderson & Jahde.  Return preparers (even Certified Public Accountants) rarely understand, and appreciate, criminal tax issues. In going to one first, you could unwittingly make an admission that becomes the linchpin of the IRS’s criminal prosecution against you.

If you have unfiled tax returns, the tax attorneys at Anderson & Jahde can help. Circumstances can cause individuals and businesses to fall behind. We also understand the stress individuals suffer when they fall behind. We can help you get back on track while minimizing, and often eliminating, the risk your situation will turn into a criminal tax investigation.

Foreign Tax Problems

Those who own an interest in certain foreign assets are required to disclose them to the IRS – failure to comply can lead to severe penalties that can equal or exceed the value of these assets. Members of our tax litigation team specialize in foreign tax problems and can assist you if you have an undisclosed interest in:

  • Foreign bank accounts
  • Foreign investment accounts
  • Foreign Trusts (as either a grantor or a beneficiary)
  • Retirement accounts in foreign jurisdiction
  • Foreign corporations, partnerships, or other businesses
  • Foreign mutual funds
  • Foreign commodities accounts (gold, silver, etc.)
  • Other foreign assets

The new global economy creates complicated income, audit, and reporting requirements. The IRS has dedicated its resources to detecting, auditing and collecting taxes from international accounts and transactions. Penalties can include deportation of non-citizens, large monetary penalties, and potential criminal charges. The Denver tax attorneys at Anderson & Jahde have the experience to ensure compliance and accuracy and crafting creative solutions to solving difficult international tax concerns.

Tax Liens & Levies

Individuals that owe Federal or State Taxes can find themselves underneath the awesome collection powers of the Government. These powers include the ability to file a tax lien, or issue levies and garnishments against bank accounts and wages. Our tax litigation attorneys represent clients before state and federal tax authorities and regularly secure collection alternatives that enable our clients to fulfill their tax obligations while eliminating the extreme hardship of a lien or levy and lift those that have already been initiated.

Depending on the taxes owed, the age of the liability, and the taxpayer’s ability to pay, the options include an installment agreement, offer in compromise, bankruptcy, and placing the debt in “Currently not Collectible” status. But determining which option is the best for any particular taxpayer, and identifying and sidestepping the pitfalls that may come along the way, requires real education, training, and experience working through these issues. Don’t be fooled by those offering to settle your debt for “pennies on the dollar.” Too often, they will charge you a fortune to take you down a path that has no possibility for success. Start by calling the attorneys at Anderson & Jahde.

IRS Notices

The IRS sends notices to change the tax you may owe, collect taxes, give taxpayers information, create a substitute tax return where none has been filed, and for other purposes. IRS Notices can be confusing, and, sometimes, carry harsh consequences for taxpayers who fail to timely respond. Of chief concern are IRS notices sent via certified mail—please do not avoid them. They are time sensitive legal documents, often providing taxpayers with important rights. Avoiding them may only exacerbate your tax problems.

For example, Statutory Notices of Deficiency (also known by their acronym, “SNOD”) are sent by certified mail to propose additional tax, penalties and interest. They also trigger a taxpayer’s right to challenge the IRS’s proposed additions by filing a Petition with the United States Tax Court. The Petition with the Tax Court must be filed within 90 days of the Deficiency Notice. Taxpayers who fail to timely Petition the Tax Court will find the IRS has assessed the uncontested tax, penalties, and interest proposed in the SNOD, and initiated collection actions for the newly established tax liability. This occurs even though the taxpayer may have been able to defeat the adjustments proposed in the Notice of Deficiency. The taxpayer will have lost a valuable opportunity to present their meritorious defenses to the SNOD, and the work to undo the assessment afterwards can be more difficult and expensive than the Tax Court proceeding would have been.

There are other IRS notices with important procedural rights for taxpayers—rights lost if timely action is not taken. For example, Collection Due Process Notices and Notices of Assessment of Trust Fund Recovery Penalties notify taxpayers of actions being proposed by the IRS. They also notify taxpayers of their rights to challenge such actions, and begin the time in which the Taxpayer must assert those rights.

Taxpayers (and, unfortunately, too many tax professionals) fail to understand the importance of IRS Notices, and the consequences of not properly and timely responding to them—the failures of which can cause unfortunate circumstances affecting taxpayers for years. The tax attorneys at Anderson & Jahde understand the importance of IRS Notices and assist taxpayers in taking the appropriate actions to protect themselves.

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