Based in Raleigh, our tax controversy attorneys represent taxpayers in disputes with the Internal Revenue Service and the North Carolina Department of Revenue involving tax liens, audits, and collections, as well as other aspects of tax controversy and litigation.
Our tax controversy clients include individuals, as well as businesses and their owners. Our tax professionals include a CPA and two attorneys with a Masters of Law in Taxation. We have represented clients in civil tax controversies involving many varied tax issues including tax shelter/sham transactions, the civil fraud penalty, worker classification, trust fund liability, innocent spouse claims, passive loss issues, and much more. We have also represented taxpayers in criminal tax matters, working with the taxpayers and their criminal attorneys in negotiating resulting tax liability
We act as counsel for clients in controversy cases regarding federal income, gift and estate taxes and state and local taxes (including excise tax and employment tax issues.).
Our tax attorneys work in conjunction with your accountant or CPA, and are experienced in representing individual and business clients facing audit by the Internal Revenue Service or North Carolina Department of Revenue and other states which our attorneys are licensed. We also negotiate with the IRS and state tax authorities over issues raised on audit and represent our clients in administrative proceedings and litigation regarding taxes. For proposed transactions involving significant unresolved tax issues, we have obtained advance rulings from the national office of the IRS. The tax professionals of Wilson Ratledge have successfully represented clients in audits where the initial IRS assessment ranged from $10,000 to tens of millions of dollars. Through our experiences in negotiation and procedure with taxing authorities, our tax professionals have managed to secure very favorable results for clients. We make no assurances or guaranties as to tax collection outcome, but our years of experience allow us to advise tax payers as to the realistic range of the potential outcomes and to proceed accordingly.
Inaccurate or ill advised tax reporting may result in substantial federal and state taxes, penalties and interest, as well as the seizure of assets. This can result from simple errors or omissions, employee theft or sometimes something as simple as spouses filing joint returns. When a business entity or an individual is delinquent in federal or state tax payments, attorneys at Wilson Ratledge can assist in resolving the debt. Our Raleigh tax controversy attorneys regularly represent clients before state and federal tax collection authorities to eliminate or reduce tax liability and develop a tax payment plan that enables the client to fulfill any obligation. Depending on the type of taxes owed and the age of the liability, the options include installment agreements, offers in compromise, uncollectable status and bankruptcy.
When you owe overdue taxes to the government, the IRS may place a tax lien on your property. An IRS lien is a document filed with your local county government putting the general public on notice that you have an unpaid debt to the federal government. The lien protects the government’s ability to collect the money it is owed. When you are notified of an impending federal tax lien, contact the tax attorneys at Wilson Ratledge. Our professionals will help you explore your options for avoiding an IRS tax lien, including setting up an installment payment agreement with the IRS.
Offers in Compromise
Offers in Compromise are a program that the IRS offers to provide delinquent taxpayers with a fresh start toward future compliance with the tax laws.
The IRS will accept an Offer in Compromise when it is unlikely that the tax liability can be collected in full and the amount offered reasonably reflects collection potential. An offer in compromise is a legitimate alternative to declaring a case as currently not collectible or to a protracted installment agreement. The goal is to achieve collection of what is potentially collectible at the earliest possible time and at the least cost to the government.
The success of the compromise program will be assured only if taxpayers make adequate compromise proposals consistent with their ability to pay and the IRS makes prompt and reasonable decisions. Taxpayers are expected to provide reasonable documentation to verify their ability to pay. The ultimate goal is a compromise which is in the best interest of both the taxpayer and the Service. Acceptance of an adequate offer will also result in creating, for the taxpayer, an expectation of and a fresh start toward compliance with all future filing and payment requirements.
Innocent Spouse Relief
Innocent Spouse Relief provides you relief from additional tax you owe if your spouse or former spouse failed to report income, reported income improperly or claimed improper deductions or credits.
If the IRS is coming after you for tax debt that started when you filed a joint return with a spouse, and you don’t know what your spouse or ex-spouse did, Wilson Ratledge can help. Our team of experienced tax attorneys can help you gather the right facts, structure them into a valid case, and present evidence to the IRS to prove your statements.