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Tax Law Attorneys

Christopher A. Gordon
Melissa C. Carpani

 

IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, Schlagel Gordon & Kinzer, LLC informs you that, unless specifically indicated otherwise, any tax advice contained within this website was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code, or (ii) promoting, marketing, or recommending to another party any tax-related matter addressed herein.

Schlagel Gordon & Kinzer, LLC offers a full range of federal and state tax services for both businesses and individuals, including tax compliance, tax controversy, offers in compromise, installment agreements, innocent spouse conflict resolution, tax law research, tax planning and, in many cases, tax preparation.  Our attorneys deal with tax and business transactions of corporations, partnerships, limited liability companies, trusts, payroll taxes, personal property taxes, real property taxes, individual and estate taxation. 

With tax controversies, SGK realizes the difficulty in dealing with the various state and federal taxing authorities on your own and that IRS and state tax regulations and tax collection laws are often not familiar and vary from jurisdiction to jurisdiction.  SGK provides the necessary barrier between its clients and the taxing authorities and enjoys a good reputation with them in providing persuasive tax positions.  SGK is experienced in handling the following types of tax controversies:

Tax Collection Actions and Tax Debt Settlement:  SGK has substantial experience in filing installment agreement requests, offers in compromise, innocent spouse relief requests and other equitable relief requests for a wide array of clientele, including those who have failed to file returns for one or more years and those who have simply been unable to pay income or payroll taxes.  SGK has negotiated millions of dollars in tax relief for its clients and maintains a focus on this aspect of its tax practice.

Tax Liens:  A tax lien gives the IRS or state agency a legal claim to a taxpayer’s property as security for tax debt. A tax lien is attached to all taxpayer property, including homes, bank accounts, cars, and real estate. If the taxpayer is a business, a tax lien can also be applied to accounts receivable.  A tax lien can affect a taxpayer’s credit rating, making it harder to borrow money, obtain a lease or mortgage or enter into other financial contracts.   SGK works with its clients to settle tax disputes in a manner that results in the removal of tax liens.

Failure to File or Late Filing of Taxes:  Failure to file a tax return or delinquent filing of taxes can be an expensive mistake. If a taxpayer owes back taxes, tax assessments could include interest charges and late-filing penalties that will increase the tax debt by 25% or more.  SGK recommends that clients file their tax returns, irrespective of whether they can pay the taxes, in order to save interest and penalties that accrue by the mere failure to file returns.  SGK can work with a client, no matter how bad a client's personal circumstances may seem, to secure a resolution with the taxing authorities based on each client’s own personal ability to pay.

Offers in Compromise and Installment Agreements: If a taxpayer has not filed income taxes for several years, or is late in filing taxes, SGK can help negotiate a payment plan with the IRS. If a client cannot afford full payment or payment under an installment agreement, we can propose an offer in compromise in the amount of tax owed with an elimination or reduction in taxes, interest and penalties, where appropriate.  An offer in compromise is an agreement between a taxpayer and the IRS or state taxing authorities to resolve tax debt for less than full payment. The compromise can reduce the amount of taxes, penalties, and interest owed if the IRS is persuaded that:

  • There is doubt about the amount of tax a taxpayer owes;
  • There is doubt that the taxpayer could ever pay the full amount of tax owed; or
  • Payment of the full amount would create an economic hardship or be unfair due to exceptional circumstances

SGK is experienced in making these arguments on behalf of its taxpayer clients.

Innocent Spouse Relief:  Many married taxpayers file a joint tax return because of certain benefits this particular filing status allows. In so doing, a taxpayer may be held responsible for taxes that result from underpayment of taxes or from IRS disallowed deductions, even if his/her spouse earned all of the income.  This is true even if a divorce decree states that a taxpayer’s spouse will be responsible for any amounts due on previously filed joint returns.  A taxpayer must meet certain conditions to qualify for Innocent Spouse Relief; if qualified, SGK will seek to relieve taxpayers from responsibility for paying tax, interest, and penalties if his/her spouse (or former spouse) improperly reported items or omitted items on a tax return.

U.S. Tax Court:  If a taxpayer’s case cannot be resolved through negotiations, SGK can help seek relief through the U.S. Tax Court and through state actions.

Estate and Probate Taxes
SGK offers services regarding estate, gift and inheritance taxation.  Estate and inheritance taxes are taxes generally based on a person’s wealth upon their date of death and are imposed in addition to income taxes.   SGK uses many common approaches to reduce or eliminate these tax issues on behalf of its clients.

SGK’s estate planning attorneys can advise clients on ways to avoid probate costs and estate taxes through estate planning.  SGK also represents heirs and benefices in estate-valuation disputes.

To schedule an appointment with one of SGK’s tax law attorneys, please contact our offices

 
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