A. David Aymond, Attorney at Law, LL.M. in Taxation        
209 Highway 22, Ste. G, Madisonville, Louisiana (985) 845-3414            27455 Hwy. 22, Ponchatoula, Louisiana (985) 845-3414

“When the people find that they can vote themselves money, that will herald the end of the republic.”

 Ben Franklin

IRS Audit, Lien and Levy, IRS Collection, Attorney Representation



    The Louisiana law firm of A. David Aymond, LLC focuses on tax law and business law matters, including taxpayer IRS representation for IRS audit issues, IRS lien and levy and collection cases.  IRS tax collection cases can involve income tax, employments tax etc. A thorough understanding of IRS procedure and tax laws of the Internal Revenue Code (IRC) is a must.  The importance of early communication and tax attorney representation cannot be overstressed.  Having a good tax lawyer is imperative.  A small tax problem may turn into a much larger one if the IRS assesses penalties and interest on a tax deficiency. If you need tax debt relief or tax resolution help give us a call. 

IRS Tax Audit Representation 

What do you do when the IRS contacts you about a tax audit of your return?  If you have a CPA or tax attorney, the call or letter my come first to the CPA or tax lawyer where he or she has a Power of attorney on file with the IRS.  If not, you may be contacted directly.  In either event, discuss the matter with your CPA, Tax Attorney or an other person authorized to practice before the IRS.  The tax audit could ultimately result in a tax assessment, interest and penalties.  The proposed tax assessment or penalty assessment could be contested in most cases by appeal to the IRS Appeal Division, but you usually must do so within thirty (30) days from receipt of what is called a 30 day letter. The IRS appeal is usually with a local office e.g. the tax appeal would normally be at the New Orleans District in the area of Southeast Louisiana that this firm serves. Where the tax audit or tax collection issue cannot be resolved at the IRS Appeal level, you have a right to further dispute the IRS assessment in U.S. Tax Court or by paying the tax and going to Federal District Court. The right to file in Tax Court is triggered when you receive a notice of deficiency.  Certain types of tax assessments may require different procedures and timing is extremely important so contact your tax lawyer or CPA immedicately upon receipt. 

IRS Form 941 and Trust Fund Recovery Penalty

    If you fail to remit withheld taxes from employees you risk personal responsibility, even where operating as a corporation or LLC.  Substantial tax penalties apply.  You do have some rights e.g. Collection Due Process or CDP hearings.  As with all such matters see your tax attorney, CPA or other persons authorized to practice before the IRS.

Statute of Limitations on IRS Tax Assessments and IRS Collection Actions

The statute of limitations on income tax assessments is typically three (3) years, but care must be taken on calculation of when this period starts and stops.  The time frame might also be suspended for a number of reasons.  The statute of limitations on tax collection by the IRS is ten (10) years with similar caveats.  Contact your CPA or Tax Lawyer familiar with these rules.

Notice of Federal Tax Lien, Federal Tax Levy

    If IRS Collection action is taken, you may receive a Notice of Federal Tax Lien followed by filing of the federal tax lien. A Federal Tax Levy could be sent to third persons to levy amounts due to you from persons that owe you money.  The Federal Tax Lien operates similar to a mortgage and attaches to property you own. There are different types of IRS tax levies and some variation of IRS Levy Form 668 will be sent to you and the person or company holding funds that are owed to you. 

IRS Collection - Tax Representation - Tax Attorney   

    Contact your Tax Lawyer or a CPA that handles your returns immediately when dealing with IRS Collection. The earlier you have a tax professional involved in this process, the more likely that severe consequences will be avoided.  There are steps that can be taken to stay IRS collection proceedings to give you time to defend the IRS collection action or at least to keep cash flow to continue paying bills and operating a business. There are IRS appeal rights available.

Offer in Compromise and Installment Agreement

    Some  national firms advertise pennies on the dollar to settle tax liabilities.  Beware of misleading advertisements, the IRS Collection Division looks at each individual situation. That being said, there are procedures in place to settle a tax debt or tax liability during an IRS Collection action. Among these are the Offer in Compromise and Installment Agreement.  You will be required to submit financial information on IRS Form 433A or 433B, which information will be examined. You will get a conference with the IRS Appeal staff to determine your ability to pay and doubt as to collectability.  Knowing how to properly value assets and the types and amounts of expenditures allowed by the IRS is important. The offer in compromise and the installment agreement are very different procedures and one type may fit your goals better.  You will typically have iRS appeal rights or IRS collection due process rights available at some point during the collection process.       

    For additional information on this and other legal topics, please give David Aymond a call at (985) 845-3414, use the contact us form.

   We represent clients from New Orleans to Baton Rouge, Louisiana, including Hammond, Mandeville, Covington, Madisonville, Ponchatoula, Amite, Slidell and other Southeast Louisiana areas. 

Practice:  Tax Lawyer, IRS lawyer, tax debt relief, tax resolution, tax attorney, tax compromise, installment payment agreement

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The information on this website is for general information purposes only and should not be relied upon for your individual legal or tax situation. Each individual situation has its distinctive facts and you should seek the advice of a licensed attorney for your specific questions and legal needs Nor does visiting this site constitute an attorney/client relationship..  

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