IRS letters, tax debt, and Tax Court.

Questions

Common questions.

• What tax work does the firm handle?

  The firm represents individuals and closely held businesses in IRS examinations, collections, penalty disputes, matters involving unfiled returns, and U.S. Tax Court cases. The practice also includes District of Columbia and Maryland tax disputes, FBAR and foreign reporting disputes, and options for past filing and reporting failures, including the IRS Voluntary Disclosure Practice and Streamlined Filing Compliance Procedures.

• Where does the firm handle tax matters?

  Federal representation may extend nationwide. State-law matters are limited to the District of Columbia and Maryland, where Mr. Powell is admitted. District of Columbia and Maryland tax disputes are disputes with those tax authorities. They are not IRS examinations, IRS collection notices, or United States Tax Court cases, and the deadlines printed on state and federal notices run independently of each other.

• Does the firm handle FBAR and foreign reporting?

  Yes. The practice includes disputes involving foreign accounts, FBAR penalties, and international information returns. FinCEN Form 114 is required under 31 U.S.C. section 5314 when the aggregate value of foreign financial accounts exceeded $10,000 at any time during the calendar year, and Form 8938 is a separate IRS return under Internal Revenue Code section 6038D. Options for addressing past filing and reporting failures include the IRS Voluntary Disclosure Practice and the Streamlined Filing Compliance Procedures.

• How does a tax matter begin?

  It begins with a document. Read what the agency actually says, identify the date printed on it, and take the step that date requires. An IRS examination usually opens with a letter such as Letter 525 or an information document request on Form 4564. A collection case usually opens with a balance notice and then a final notice of intent to levy, LT11 or Letter 1058, which carries a 30-day hearing right. A Notice of Deficiency, Letter 3219, starts the Internal Revenue Code section 6213(a) petition period.

• Do I need a lawyer for an IRS or tax letter?

  Not always. Many notices are answered by filing the return, paying the balance, or sending the document the letter asks for, and the IRS publishes instructions for each. A lawyer earns the fee when the amount is contested, when the communications need attorney-client privilege rather than the narrower Internal Revenue Code section 7525 privilege, or when the next forum is the United States Tax Court, which requires admission under Tax Court Rule 200. Read the notice and calendar the date printed on it either way.