Can a Tax Attorney Really Negotiate with the IRS? Here’s What to Know

Owing back taxes, getting an audit notice, or facing IRS enforcement is stressful. Collection letters, threats of levies or wage garnishment, and the fear of audits or criminal exposure leave many people feeling overwhelmed and unsure where to turn. Waiting or guessing can make matters worse. Interest and penalties keep growing, the IRS can escalate to liens or bank levies, and a misstep in communications or paperwork can close off relief options you might otherwise qualify for. For business owners and individuals in Dallas, Fort Worth, and Frisco, tax problems can threaten livelihoods, reputations, and long-term financial goals. A qualified tax attorney can step in, analyze your case, and negotiate directly with the IRS on your behalf. Tax attorneys are legally empowered to represent you once you file a Power of Attorney (Form 2848) and can pursue relief options such as Offers in Compromise, installment agreements, penalty abatements, or Currently Not Collectible status. When tax risk is high, professional legal advocacy often preserves options and reduces exposure. If you need help with IRS tax problems or want a clear plan, the Law Offices of Nick Nemeth can evaluate your situation and represent you before the IRS.

What Is a Tax Attorney and What Do They Do?

A tax attorney is a lawyer who specializes in tax law, from filing and compliance issues to high-stakes negotiations and litigation. Unlike general practitioners, tax attorneys combine legal training with tax expertise to interpret statutes, challenge IRS positions, and craft strategies that consider both legal risk and practical outcomes. They are a distinct resource from CPAs or enrolled agents when legal advocacy, privileged legal advice, or courtroom representation may be needed.

Core functions of a tax attorney

• Legal representation before the IRS: With a properly filed Form 2848 (Power of Attorney), a tax attorney can receive confidential IRS communications, speak for you, and enter into negotiations. This formal representation is required for most advocacy beyond basic taxpayer contact.
• Assessment and legal analysis: Attorneys evaluate audit exposure, penalty risk, and possible defenses. They identify legal arguments, statutory exceptions, and procedural errors the IRS may have made. These assessments guide whether to litigate, settle, or pursue administrative relief.
• Negotiation and resolution: Tax counsel prepare and present settlement options such as Offers in Compromise, installment agreements, partial payment arrangements, or requests for penalty abatement. A skilled attorney frames financial data and legal arguments to improve the chance of acceptance.
• Collection defense and enforcement avoidance: Attorneys work to stop or reverse levies, release liens, and obtain stays of enforcement while resolving underlying issues. Early, accurate responses to IRS notices often prevent escalation.
• Audit and litigation representation: In audits or appeals, tax attorneys manage document requests, craft responses that protect client rights, and represent clients in the IRS Office of Appeals or the federal Tax Court when necessary.

Why an attorney may be the right choice

If the IRS has initiated serious collection, you face potential criminal exposure, you have complex business or international tax issues, or your case involves large liabilities and penalty risk, an attorney adds legal authority and negotiation leverage. Attorneys bring both legal privilege and experience in front of IRS revenue officers and appeals personnel. That combination can change outcomes and reduce long-term risk.

Types of Situations Where a Tax Attorney Can Help

Tax attorneys apply legal training to tax problems that go beyond routine return prep. Below are the most common situations where having a lawyer changes outcomes, and what an attorney actually does in each case.

1. Representation When You’re Facing Criminal or Civil Legal Consequences

When the IRS raises questions about fraud, willful evasion, or serious misreporting, the stakes include criminal prosecution, civil fraud penalties, or both. A tax attorney will:

• Evaluate whether the matter is civil or criminal and explain exposure and defenses.
• Protect your constitutional rights (including privilege against compelled self-incrimination).
• Coordinate interviews with criminal investigators and negotiate limited disclosure where possible.
• Work to resolve allegations through civil settlement when appropriate, or defend you in prosecution if necessary.

2. Guidance When You Need Financial Relief from Tax Debt

Large tax balances, repeated notices, or enforcement threats (levies, bank levies, wage garnishments, or tax liens) require strategic negotiation. Tax attorneys negotiate with the IRS to:

• Secure Installment Agreements or direct-debit payment plans that prevent levies.
• Prepare and submit Offers in Compromise (OICs) when collectibility is in doubt.
• Request Penalty Abatement based on reasonable cause or first-time penalty relief.
• Obtain Currently Not Collectible (CNC) status for clients in severe hardship.

An attorney packages financial statements and legal arguments to maximize the chance of acceptance and to coordinate tax and non-tax consequences (including tax forgiveness exposure).

3. Tax Advice: Planning, Compliance & Complex Returns

Tax attorneys advise proactively and reactively on issues such as:

• Business tax structuring, disputes over deductions, and state-federal coordination.
• International tax compliance (FBAR, FATCA, cross-border reporting) and voluntary disclosure when foreign accounts or income are involved.
• Audit defense: drafting responses, assembling substantiation, and representing you in Appeals or Tax Court.
• Coordinating legal and accounting strategies when CPAs or enrolled agents handle return preparation, while attorneys handle negotiation and court matters.

If you are receiving enforcement notices, facing an IRS audit, dealing with potential criminal exposure, or confronting substantial tax debt, a tax attorney provides legal tools and procedural advantages that non-attorney advisors cannot. For residents and businesses in Dallas, Fort Worth, and Frisco, the Law Offices of Nick Nemeth offers local experience in negotiation, litigation, and tax-risk management – and will evaluate whether attorney representation is the right next step for your case.

Can Attorneys Negotiate With the IRS?

Short answer: yes – tax attorneys can and routinely do negotiate directly with the IRS on behalf of clients. But how that works in practice, what attorneys can actually do, and when their involvement matters most are important to understand.

How attorneys get authority to negotiate

Before an attorney can speak to the IRS about your case, you or your attorney must file Form 2848 (Power of Attorney). That form formally authorizes the attorney to receive confidential IRS information and represent you on the tax years and issues listed on the form. Without Form 2848 on file, the IRS will not treat an attorney as your official representative.

The tax code also protects your right to counsel. If you tell the IRS you want a lawyer, the IRS should stop direct collection communications while representation is arranged. That legal protection levels the playing field and prevents you from being forced into an uninformed position.

What attorneys actually negotiate for

Tax attorneys use several concrete tools when negotiating with the IRS:

• Installment agreements — structured monthly payment plans to avoid levies and garnishments.
• Offers in Compromise (OICs) — settle an eligible liability for less than the full amount when collectibility is doubtful.
• Penalty abatement — requests to remove or reduce penalties for reasonable cause or first-time abatement.
• Currently Not Collectible (CNC) status — ask the IRS to pause collection when a taxpayer truly cannot pay.
• Innocent spouse relief and related equitable relief where appropriate.
• Appeals, Collection Due Process (CDP) hearings, and litigation — if negotiation stalls, attorneys can pursue administrative appeals and, when necessary, litigation in Tax Court or federal court.

Skilled counsel packages financial documentation and legal reasoning to present the strongest case for acceptance of one of these remedies. Attorneys know how to present Offers in Compromise and other proposals in the format the IRS evaluates, increasing the chance the IRS will view the request favorably.

What having an attorney changes, and what it does not

• What it helps with: Attorneys reduce procedural risk, protect rights (including privilege where applicable), stop or slow collection actions while negotiating, and present legal arguments or statutory defenses the IRS may not have considered. Early attorney involvement often prevents levies, liens, or escalated enforcement.
• What it does not guarantee: An attorney cannot change tax law or promise a particular numerical outcome. Success depends on facts, documentation, and applicable law. Attorneys cannot force the IRS to accept a settlement that does not satisfy statutory or administrative standards.

Typical negotiation process (what you can expect)

1. Power of attorney filed (Form 2848) so the attorney can act for you.
2. Initial case evaluation — attorney reviews returns, notices, bank records, and prior IRS correspondence to identify exposure and relief options.
3. Strategy selection — propose the best path (installment agreement, OIC, penalty request, CNC, or appeal).
4. Documentation & submission — assemble financial statements, supporting exhibits, and legal arguments in the format IRS expects.
5. Negotiation & follow-up — attorney communicates with revenue officers or appeals officers, responds to IRS questions, and protects your rights throughout the process. If negotiation fails, counsel moves to appeals or litigation as appropriate.

When an attorney’s negotiation matters most

• Large tax debts, repeated enforcement notices, or imminent levies/attachments.
• Potential criminal exposure or fraud allegations.
• Complex business or international tax issues where the legal stakes are high.
• Cases where appeals or litigation are likely.

If you are facing IRS notices, enforcement, or large tax debt, an experienced tax attorney can analyze your options, file Form 2848, and begin negotiations immediately. For residents and businesses in Dallas, Fort Worth, and Frisco, the Law Offices of Nick Nemeth provides local, experienced tax representation, from installment agreements to Offers in Compromise, penalty abatement requests, CDP hearings, and litigation when necessary.

What Are Some Tax Attorney Strategies That Can Help During IRS Negotiations?

When the stakes are high, skilled tax attorneys use a structured playbook, not guesswork, to improve results. Below are the principal strategies a tax attorney at the Law Offices of Nick Nemeth will typically deploy when negotiating with the IRS on your behalf.

1) Initial Assessment & Case Evaluation

• Gather the paper trail: collect tax returns, IRS notices, bank statements, pay stubs, business books, prior correspondence with the IRS, and any third-party notices (levy, lien, summons).
• Identify exposure and deadlines: determine what years are at issue, which notices trigger 30-day rights (e.g., Collection Due Process), and any statute-of-limitations or filing defects the IRS may have.
• Risk triage: separate urgent enforcement risks (levies, wage garnishment, passport-related certified debts) from negotiable balance issues.
• Privilege and representation: prepare and file Form 2848 (Power of Attorney) so your attorney receives IRS communications and can act for you.
  This intake phase sets the factual and legal foundation for every negotiation move.

2) Strategy Development, IRS Compliance Check, & Documentation

• Compliance check: confirm all required tax returns are filed and current-year deposits/taxes are being paid. The IRS will often refuse relief if filings are delinquent.
• Financial packaging: prepare a clear, itemized financial statement (income, expenses, assets, liabilities) in the format the IRS expects. Accurate, well-documented statements increase credibility and speed. Typical documents include Forms 433-F/433-A (or a custom statement), bank records, proof of expenses, and asset valuations.
• Select the most appropriate resolution path: based on ability to pay and legal exposure, propose one of the administratively available remedies (Installment Agreement, Offer in Compromise, CNC, penalty abatement) or prepare to appeal the assessment. Attorneys calculate “reasonable collection potential” and present offers accordingly.
• Legal framing: couple the financial package with statutory and administrative arguments – e.g., demonstrating reasonable cause for penalty abatement, showing that an OIC meets the IRS’s collectibility standards, or identifying procedural defects in the IRS’s assessment.
• Proactive creditor management: where levies or liens are threatened or in place, attorneys request emergency releases or lien withdrawals while negotiations proceed, using hardship standards and legal authority where appropriate.
  Thorough documentation and legal framing turn negotiations from informal requests into persuasive, rule-based proposals.

3) Resolution & Finalization

• Negotiate terms and follow the process: attorneys speak directly with revenue officers or appeals officers, respond to information requests, and amend proposals based on IRS feedback. They know which concessions are realistic and which undermine credibility.
• Use available administrative remedies: if an initial negotiation is denied, counsel can file appeals (Collection Due Process hearings, appeals requests) and escalate to litigation in Tax Court or federal court when appropriate. Appeals often succeed where frontline negotiations do not.
• Draft enforceable agreements: when the IRS accepts a remedy, attorneys ensure the terms are documented correctly (payment schedules, releases, lien subordination or withdrawal language) and confirm any conditions (e.g., compliance periods) are practicable for the client.
• Coordinate tax consequences: if relief involves forgiven debt, attorneys coordinate with tax counsel to anticipate cancellation-of-debt income and plan for any resulting tax liability or mitigation (insolvency analysis, bankruptcy exceptions).
• Ongoing compliance monitoring: after resolution, counsel monitors filings and payments to avoid defaults that would reopen enforcement.
  Execution is as important as the proposal: an attorney both bargains and locks in durable protection.

Practical checklist attorneys typically request from clients

• Last 3 years of tax returns and any amended returns
• Most recent IRS notices and assessment transcripts (if available)
• Bank statements and check registers (3–6 months)
• Pay stubs, proof of pension or other income, business profit/loss statements
• Mortgage/auto statements, appraisals, and documentation of essential living expenses
• Copies of prior offers, settlement letters, or lien/levy notices

Providing these promptly accelerates negotiations and reduces the chance the IRS will default to enforcement.

What an Attorney Cannot Do (and why candor matters)

• An attorney cannot change tax law or guarantee a specific numeric outcome. The IRS applies statutory standards and administrative rules; success depends on the factual record and legal arguments available.
• Full candor with your attorney is essential. Concealing facts or assets undermines strategy, can lead to adverse findings, and in extreme cases may create criminal exposure. Honest, immediate disclosure lets counsel craft defensible positions.

If you are facing IRS enforcement, audit, or substantial tax debt, the Law Offices of Nick Nemeth can perform the assessment, assemble your financial package, file Form 2848, and begin negotiations on your behalf. 

Can an Attorney Lower Your Owed Taxes?

Short answer: yes – in many cases, a tax attorney can help reduce what you ultimately pay, but they do it by pursuing specific, legally established remedies rather than by “waving a magic wand.” Below are the principal relief tools attorneys use, what each can do, who typically qualifies, and how an attorney improves the odds of success.

Offer in Compromise (OIC)

What it does
An Offer in Compromise lets eligible taxpayers settle an IRS liability for less than the full amount owed when the IRS determines the offered figure is the most it can reasonably expect to collect.

Who may qualify?
Qualification is based on “reasonable collection potential” (RCP): the IRS looks at your income, assets, allowable living expenses, and what it could expect to recover through collection. Tax attorneys evaluate RCP and decide whether an OIC is a realistic option.

How an attorney helps

• Prepares a complete financial package (Forms 433-A/433-B or equivalent) in the format the IRS expects.
• Calculates RCP precisely, so the offer is neither obviously inadequate nor unnecessarily high.
• Anticipates and documents allowable expenses and asset valuations to reduce the IRS’s collection estimate.
• Presents legal and equitable arguments (effective tax administration) when classic collectibility analysis alone does not tell the whole story.

Because OICs are scrutinized carefully and often rejected for incomplete or weak documentation, attorney preparation materially increases the chance of acceptance.

Tradeoffs and timeline
OICs require full disclosure and sometimes a nonrefundable application payment. The review can take months. Even if accepted, certain conditions (compliance years) often apply. An attorney advises whether the likely savings justify the time and cost.

Penalty Abatement

What it does
Penalty abatement reduces or eliminates penalties (failure-to-file, failure-to-pay, accuracy-related penalties) that can dramatically increase a tax balance.

Who may qualify?
Common grounds are reasonable cause (serious illness, natural disaster, incorrect professional advice, etc.) or first-time penalty relief for otherwise compliant taxpayers. An attorney documents the factual basis and legal standards for relief.

How an attorney helps

• Crafts a concise, evidence-based request demonstrating reasonable cause.
• Cites precedent and IRS administrative criteria to support abatement.
• Pursues administrative appeals if the initial request is denied.

Penalty abatement is often low-cost and can yield an immediate reduction in the balance due when successful.

Installment Agreements

What it does
Installment agreements (including streamlined online options) let you pay over time. They do not reduce principal but prevent immediate enforcement (levies, garnishments) and spread out payments to a manageable monthly amount.

How an attorney helps

• Matches the right plan (short-term, long-term, direct debit) to your cash flow.
• Negotiates terms that limit fees and default risk.
• Prepares the financial picture, so the IRS sees the agreement as reasonable and sustainable.

For taxpayers who can pay in full over time, an attorney’s involvement minimizes administrative friction and the risk of default.

Currently Not Collectible (CNC) Status

What it does
CNC status temporarily suspends collection activity (levies, garnishment) when a taxpayer cannot afford to pay without sacrificing basic living expenses. Interest may continue to accrue, but enforced collection stops while the status holds.

How an attorney helps

• Assembles the evidence of financial hardship required for CNC (detailed living expense documentation, income verification).
• Argues why levy relief or an emergency release is appropriate while CNC is under review.

CNC can be lifesaving for taxpayers experiencing job loss, medical emergency, or other severe hardship.

Innocent Spouse Relief

What it does
Innocent spouse relief can remove tax liability from one spouse when the other spouse’s erroneous items caused the deficiency, and it would be unfair to hold the innocent spouse responsible.

How an attorney helps

• Evaluates eligibility under the innocent spouse and equitable relief standards.
• Prepares the Petition and supporting evidence, and represents the client in administrative review or appeals.

In complex family or business situations, an attorney ensures the strongest possible presentation of innocence and unfairness.

Full Payment of Tax Liability

What it does
Paying in full is the simplest way to stop interest and collection, and it immediately releases most enforcement actions (bank levies are released once funds are returned).

How an attorney helps
Even in full-payment situations, counsel coordinates timing, secures lien withdrawals when appropriate, negotiates release of levies, and confirms proper accounting, so payments are applied correctly. Attorneys also advise when a partial payment plus an administrative remedy (e.g., penalty abatement) produces a better net outcome.

Putting It Together: Realistic Expectations

• Not every case yields a dollar reduction. Some clients benefit most from payment plans or penalty abatement rather than outright forgiveness.
• Documentation wins. The common thread across successful resolutions is complete, accurate documentation presented in the IRS’s expected format. Attorneys bring experience assembling persuasive financial packages and framing legal arguments.
• Timing and urgency matter. Early representation often prevents levies or lien filings and preserves relief options that vanish once assets are seized or the statute of limitations changes.

When Should You Hire a Tax Lawyer?

If you are uncertain whether to call an attorney, here are clear, practical trigger points where legal help usually changes the outcome. Below each situation, you’ll find what an attorney does, why timing matters, and what to bring to your first meeting.

1. You Receive an IRS Notice of Audit or Legal Action

When the IRS opens an audit, issues a summons, or sends a Notice of Intent to Levy, the stakes rise immediately. An attorney will:

• Explain your audit rights and deadlines, file the correct Power of Attorney (Form 2848), and prevent inadvertent admissions.
• Manage document production so you provide what is required without creating additional exposure.
• Represent you in meetings, Appeals, or Tax Court if necessary.

Act quickly. Early counsel can narrow the audit scope, preserve defenses, and often avoid escalation to liens or levies.

2. You Are Facing Significant Tax Debt or Penalties

Large balances or recurring penalties create urgent collection risk – bank levies, wage garnishments, or public liens. A tax lawyer will:

• Calculate your “reasonable collection potential,” prepare accurate financial statements, and pursue appropriate relief (installment agreements, Offers in Compromise, CNC).
• Request emergency levy releases and negotiate practical payment terms.
• File administrative appeals if the IRS mistakes your case.

The sooner you engage counsel, the more options remain available and the less likely enforcement becomes irreversible.

3. You Have Complex Tax or Business Situations

Complexity increases the chance for error and the value of legal strategy: multi-year partnerships, large depreciation or basis disputes, S-corp/partnership allocations, or tangled state/federal issues. Attorneys:

• Build integrated strategies with tax, accounting, and business goals in mind.
• Coordinate amended returns, protective claims for refund, and audit defenses that minimize business disruption.

Complex cases benefit from counsel who can translate technical tax rules into defendable positions.

4. Your Business Is Under Review or Facing Enforcement

When payroll taxes, employment tax liabilities, or corporate-level exposures are at issue, personal liability for owners can be real. A tax attorney will:

• Negotiate with revenue officers, seek installment or collection-suspension remedies, and defend against personal assessments.
• Advise on corporate governance steps to limit future exposure while resolving current liabilities.

5. You Have International Tax or Cross-Border Issues

Foreign accounts, FBAR/FATCA reporting, offshore income, or voluntary disclosure matters raise unique legal and criminal risks. Attorneys experienced in international tax help you:

• Navigate disclosure programs, prepare accurate compliance filings, and reduce criminal exposure where possible.
• Coordinate with foreign counsel, accountants, and the IRS to resolve reporting failures with minimized penalties.

Practical checklist — what to bring to your first meeting

• Recent IRS notices and transcripts (if available)
• Last 2–3 years of tax returns and any amended returns
• Bank statements, pay stubs, business P&L and balance sheets
• Any collection correspondence (levy, lien, garnishment notices)

If your matter involves audits, large debts, potential criminal exposure, complex business transactions, or international reporting, hire a tax attorney early. The Law Offices of Nick Nemeth can promptly evaluate your case, file the necessary authorizations (Form 2848), and begin negotiations or defenses tailored to your circumstances. 

Take Control of Your Tax Concerns Now: Contact the Law Offices of Nick Nemeth

If IRS notices, audits, or growing tax debt keep you up at night, you do not have to face them alone. At the Law Offices of Nick Nemeth our tax attorneys for IRS matters provide focused legal representation across Dallas, Fort Worth, and Frisco. We handle everything from audit defense and installment agreements to Offers in Compromise, penalty abatement, and litigation.

Ready to begin? Call (972) 426-2944 or complete our contact form to schedule a confidential consultation. We will explain next steps, fees, and the likely timeline for resolving your IRS issues. 

Frequently Asked Questions

1. Can a tax attorney really negotiate with the IRS on my behalf?

Yes. Once you sign Form 2848, a tax attorney is an authorized representative and can negotiate directly with revenue officers and appeals personnel, submit Offers in Compromise, request penalty abatements, and arrange installment agreements.

2. Can a tax lawyer prevent a tax levy?

An experienced tax attorney can often stop a levy by negotiating an installment agreement, requesting an emergency levy release for hardship, or filing for Currently Not Collectible status. Timing matters, so contact an attorney as soon as you receive a levy notice.

3. Is hiring a tax attorney better than using a CPA or enrolled agent?

It depends. CPAs and enrolled agents are highly capable of return preparation and many negotiations. A tax attorney is necessary when legal advocacy, privilege, court representation, or criminal exposure is involved. For large liabilities, enforcement risk, or litigation, attorney representation is usually best.

4. Why is it important to act quickly in tax debt resolution scenarios?

Delays increase interest and penalties and give the IRS time to escalate enforcement, including levies, liens, and garnishments. Acting early preserves more relief options, such as Offers in Compromise or penalty abatement, which can vanish once assets are seized.

5. What specific skills are crucial for a tax attorney dealing with the IRS?

Important skills include deep knowledge of tax law and IRS procedures, experience preparing financial statements in the format the IRS expects, negotiation experience with revenue officers, and litigation ability for appeals or Tax Court.

6. How can you verify a tax attorney’s track record with the IRS?

Ask for examples of similar matters the attorney handled, request references, and confirm professional credentials and standing. During a consultation, ask how often they obtain OICs, penalty abatements, or levy releases in matters like yours.

7. Can a tax attorney help with a tax audit?

Yes. A tax attorney can prepare responses to audit requests, represent you at meetings with IRS auditors, negotiate adjustments or settlements, and take the case to the IRS Office of Appeals or Tax Court if necessary.

8. How would a tax lawyer help when requesting a payment plan?

A tax attorney evaluates which installment agreement fits your cash flow, prepares the supporting documentation, negotiates terms to limit fees or defaults, and can set up direct debit to reduce the chance of missed payments.

9. Can an attorney help during the investigation stage when negotiating with the IRS?

Absolutely. During investigations, an attorney protects your rights, advises on whether to provide documents or testify, and coordinates responses that limit exposure while maintaining credibility.

10. Do tax attorneys offer free consultations?

Many firms, including the Law Offices of Nick Nemeth, offer a confidential initial consultation to review your matter and recommend next steps. Confirm fee policies for extended representation during the first call.

11. How much does it cost to hire a tax attorney in Dallas?

Costs vary by complexity. Simple matters have lower fixed fees, while negotiations, appeals, or litigation are billed either at hourly rates or via agreed retainers. We provide a clear fee estimate during the initial consultation.

12. Will the IRS treat my case differently if I have a tax attorney?

The IRS recognizes authorized representatives and communicates through them once Form 2848 is filed. Legal representation does not guarantee a different result, but it ensures proper procedure, protects rights, and often improves the quality of negotiation and outcomes.

13. What should I prepare before meeting with a tax attorney?

Bring IRS notices, copies of the last 2 to 3 years of returns, bank statements, pay stubs, business financials, and any correspondence from the IRS. The more documentation you provide, the faster an attorney can evaluate and act.

14. How do I find a qualified IRS tax attorney near Fort Worth who can help with tax debt negotiation?

Start with a firm that focuses on tax controversy and debt relief, has experience negotiating Offers in Compromise and installment agreements, and provides local representation. Contact the Law Offices of Nick Nemeth for a case evaluation tailored to Fort Worth and the surrounding areas.

15. What types of IRS issues can a tax lawyer near me handle in the Dallas–Fort Worth–Frisco area?

Local tax attorneys handle audits, collection matters, installment agreements, Offers in Compromise, penalty abatement requests, lien and levy releases, innocent spouse claims, criminal tax investigations, and representation in Tax Court.

16. Can a tax attorney help with international tax problems?

Yes. Attorneys experienced in international tax assist with FBAR and FATCA issues, voluntary disclosures for undisclosed foreign accounts, cross-border tax planning, and minimizing criminal or civil exposure related to foreign income.

17. How long does an IRS negotiation usually take?

Timelines vary. Installment agreements can be arranged in days to weeks, Offers in Compromise often take months, and appeals or litigation can take many months to years, depending on complexity. Your attorney will provide a timeline estimate after initial review.

18. Should I hire a tax attorney before responding to an IRS notice?

If the notice threatens enforcement, significant penalties, or an audit, it is wise to consult an attorney before responding. An attorney can ensure your reply does not inadvertently waive rights or create additional exposure.

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