As the list below is by no means all-inclusive, please feel free to inquire about a service if you do not see it listed. If it is not a service I provide, I would be more than happy to refer you to a qualified professional.

My entire career, from 1966 until 1993, was spent collecting taxes for the United States Government. During this time I worked on the most complicated cases that included, seizures & sales, lien discharges, subordinations & foreclosures, suits, bankruptcy discharges, collateral agreements, estate taxes, transferee assessments and offers in compromise.

From 1983 to 1993 I was an offer specialist negotiating hundreds of successful offers.

I have subsequently retired in 1993, after a total of thirty-one years of federal service. Since retiring, I have been in business representing serious clients who want to extricate themselves from their tax problems. I have the advantage of seeing both sides of the table and can assist you with your individual situation.

Contrary to popular belief, this is not a government give away program. Beware of the advertisements that indicate:PENNIES ON THE DOLLAR! Maybe not! An offer is a detailed examination of all the assets and liabilities of the taxpayer and can be very time consuming. The average offer can take from six to twelve months and sometimes longer.

The IRS will basically consider three types of offers:

DOUBT AS TO LIABILITY: I don't owe it! This is similar to an audit reconsideration. The taxpayer may have been erroneously assessed for income taxes and possibly payroll taxes. An offer can be filed for what you thing the correct amount should be.

DOUBT AS TO COLLECTIBILITY: I can't pay it! These type of proposals represent the majority of offers received by the government. An acceptable offer must equal the total equity in assets and future income collection potential. If this offer is accepted, the government may also implement a future income collateral agreement and/or waiver of losses.

EFFECTIVE TAX ADMINISTRATION (ETA): In certain circumstances the government may accept an offer even if the taxpayer has the assets and ability to pay the tax liability in full. This could apply to individuals with serious health problems which could be considered under the special circumstances criteria. These offers are very difficult to have accepted and the facts and circumstances must be compelling.

The State agencies also have Offer in Compromise programs which are basically similar to the above criteria for the IRS. The California Franchise Tax Board (FTB) has a full time offer unit which will consider most reasonable proposals.

Obviously, all income and expenses must be thoroughly documented.

Collection Due Process (CDP): The CDP hearing provisions give the taxpayer an opportunity for an independent review to insure that collection action is warranted. An appeal must be filed within 30-days after certain final notices are received from the IRS. If this appeal is unsuccessful, you then have the right to file a petition in Tax Court.

Fast Track Mediation (FTM): The taxpayer can request FTM and secure an "Agreement to Mediate". Both sides must agree to mediate and the appeal must be forwarded to the local Appeals office within three days. This program is highly touted by the government and has a sucess rate of approximetely 85%.

Collection Appeals Program (CAP): This is essentially "Instant Justice" and similar to binding arbitration. A Form 9423 must be filed with a Group Manager who must then transfer this file to Appellate within 48-hours. Appeals then must render a decision within 5-days. Both sides must adhere to the decision and there are no rights to file a petition in court.

Taxpayer Advocates Office: If all normal procedures have failed, you can contact this special office. The Advocates have the ability to cut through the usual "red tape" and resolve many problems. In a recent case; Mrs."W" discovered that the statute for collection,(CSED),on her joint income taxes with her former spouse had been extended for another 6-years. A copy of the Form 900 waiver revealed that the ex-husband had forged her signature on this waiver. A handwriting expert's report and Form 911 to the Advocate's office removed her name from these assessments which had expired. Savings to Mrs. taxpayer; $100,000.00!

In a recent case; Mr. "A" discovered that the State of California, EDD, had recorded notices of Liens against him in 6-Counties in the State of California. These liens were for payroll taxes assessed under Section 1735 of the California Revenue and Taxation Code for unpaid payroll taxes assessed 12-years past, that were due from a defunct corporation. These assessments against Mr. "A" were all currently in uncollectible status. A petition was filed with the California Unemployment Insurance Appeals Board for a reassessment or review. Subsequently a hearing was scheduled before a Chief Administrative Law Judge to hear the merits of this case. After numerous conferences with the EDD it was decided that the assessment against Mr. "A" had no merit and all the liens recorded against him were immediately released. Savings to Mr. "A"; 1.9 million dollars!

Recent legislation; H.R. 4250, "The American Jobs Creation Act of 2004" has dramatically implemented the traditional IRS installment agreement. These are also called "Partial Payment Installment Agreements (PPIA)." Before; the government could only enter into a payment agreement if the taxes would be paid in full before the collection statute of limitations (CSED) expired. Under these new rules, the government can enter into a payment agreement for the remaining life of the 10-year statute, plus a 5-year extension, regardless of whether or not the taxes will be paid in full. These payment agreements, however, are subject to periodic review to ascertain if the taxpayer can increase the monthly payments. This arrangement is very similar to the offer in compromise where the taxpayer agrees to pay the amount offered over the life of the statute. It is currently being implemented by many revenue officers and is a viable option to resolving a tax debt.

Some reasons for abatement of penalties might be; Ignorance of the Law, Mistake was Made, Forgetfulness, Death, Serious Ilness, or Unavoidable Absence, Unable to Obtain Records and Advice.

I can assist you in preparing the proper foremat to abate these penalties in order to reduce your overall liability.

In a recent case; Mr."JG" was assessed failure to file (FTF) and failure to pay (FTP) penalties along with being assessed two years Substitute for Returns (SFR's) by the IRS. At this time, Mr. JG indicated that he was a tax protester and attempted to convince the Government that the personal income taxes were unconstitutional. IRS was decidely unsympathetic! It was later discovered that Mr. JG was talked into joining a protest group by his mother and brother and that he actually had no prior experience with filing and/or paying personal income taxes. He essentially thought he was joining some sort of a "club". A declaration, signed under penalty of perjury, was submitted by Mr. JG to IRS indicating his complete and total ignorance of what he was doing along with his lack of education. Also, since these back two delinquencies the taxpayer has filed and remained current on his filing requirments.

The Government accepted his explaination and abated all late filing and late payment penalties. After a reduction of $16,000.00, Mr.JG paid the remaining balance to IRS in full by refinancing his home. He has remained current since.

Filing bankruptcy is a very serious matter. Some taxes can be discharged if they meet certain stringent criteria. I can help you to determine which taxes can be discharged and assist you in detailed pre-bankruptcy planning.