Tax collection procedures including but not limited to:

• Legal Advising after notice and demand for payment after assessment
• Fighting tax liens (general (unfiled) and filed) upon assessment and failure to pay
• Arguing ten (10) year statute of limitation on tax collections
• Properly applying offsets of refunds to the correct tax year
• Attorney for fighting tax levies on the taxpayer and third parties
• Legal arguing constitutional protections on IRS levies
• Legal arguing no beneficial ownership in property seized by the IRS
• Legal advising on priority of tax liens
• Drafting and negotiating many installment agreements under 433-A, 433-B, 433-F, 433-D and 9465
• Assisting clients with the streamlined installment agreements
• Assisting taxpayers into the position of “currently not collectible or collection suspense”
• Assisting taxpayers with offers in compromise under 656, including offers as to doubt as to collectability and doubt as to liability;
• Assisting bankruptcy attorneys with determining the different types of taxes that can and cannot be discharged;
• Arguing taxpayer is not a responsible person and subject to the trust fund recovery tax;
• Requesting protection from IRS collection efforts under collection appeals program and collection due process
• Innocent spouse relief including joint liability relief under 6015(b); divorced or legally separated relief under 6015(c)
• Equitable tax relief under 6015(f)
• Separate liability relief for community property items
• Nominee and transferee liability
• Liability for trust fund taxes
• Trust fund penalty under 6672
• Beneficiary and donee liability under 6324
• Ryan Gardner is an attorney and CPA with an excellent reputation and is located in the Dallas area and East Texas for your convenience. Contact one of our offices for legal representation or advice on Business Tax Law in Texas.