Tax controversy. One focus.

Yes, and it does not need a court order to do it. Before levying, the IRS generally must send a Final Notice of Intent to Levy and give you 30 days to request a Collection Due Process hearing. Requesting that hearing on time suspends levy action while Appeals reviews the case. A wage levy is continuous, meaning it keeps taking from every paycheck until the debt is resolved or released. A bank levy is a one-time snapshot, and the bank holds the funds for 21 days before sending them, which is often just enough time to act. Seizure of a primary residence is different: it requires court approval and is rare.

For most people, no. The overwhelming majority of tax matters are civil, and owing money is not a crime. But criminal exposure is real for the minority of cases that involve intent — deliberately concealing income, falsifying records, or lying to an agent — rather than an honest mistake or an inability to pay. The warning signs worth taking seriously are contact from IRS Criminal Investigation rather than a revenue agent, questions that seem aimed at what you knew and when, or an examination of a return you know is not accurate. If any of that applies, stop talking to the IRS and speak with an attorney before your next contact.

Yes, that can be an option — but it is not automatic, and it happens far less often than the advertising suggests. An Offer in Compromise is evaluated on reasonable collection potential, which is essentially what the IRS calculates it could collect from your income and assets over time. If that figure exceeds the debt, the offer is rejected regardless of how difficult your circumstances feel. Many people who are told over the phone that they qualify do not. An honest answer on that question is worth more to you than an optimistic one, and it is the first thing worth determining.

Usually three years from the date the return was filed or the date it was due, whichever is later. That period extends to six years when more than 25 percent of gross income was left off the return, and there is no deadline at all where no return was filed or where a return was false or fraudulent. Unfiled foreign information returns can also prevent the clock from starting. In practice most examinations begin within about two years of filing. If an examination is still open as the deadline approaches, the IRS will often ask you to sign an extension, and whether to agree is a decision worth discussing before you sign it. This assessment period is separate from the ten-year period the IRS has to collect a tax once it has been assessed.

Generally ten years from the date the tax was assessed, after which the debt expires by operation of law. That clock is not always running, though. It pauses while an Offer in Compromise is pending, during bankruptcy, while a Collection Due Process hearing is open, and during extended periods outside the country. In some cases the most valuable thing an attorney can do is calculate where you actually sit on that timeline, because the right strategy for someone with eight years remaining is not the right strategy for someone with fourteen months.

This is more common than people assume and more fixable than it feels. The IRS generally looks for the last six years of returns to consider you in compliance, and coming forward voluntarily is treated very differently from being found. If the IRS has filed substitute returns on your behalf, those are usually calculated in the worst possible light, without deductions or credits you were entitled to, so the balance shown is often far larger than what you actually owe.

For a simple matter, often yes. If you received a CP2000 about a 1099 you forgot, and the numbers are clearly right, you can respond yourself and save the cost of counsel. That said, plenty of people would simply rather not deal with the IRS directly, even for something straightforward, and knowing how the agency actually works can mean a simple matter gets resolved faster and with less back-and-forth. It becomes a different question when the facts are contested, when the return has a problem you already know about, when the amount is significant, or when an examiner has started asking about intent. What you say to the IRS is not privileged and cannot be unsaid.

For return preparation and many straightforward examinations, a CPA or enrolled agent is often the right choice and costs less. An attorney matters when the dispute may be litigated, when the facts are contested, when penalties involve intent, or when the attorney-client privilege needs to protect the conversation itself.

Not reliably. A narrow federal privilege can cover tax advice from an accountant, but it never applies in a criminal matter, does not cover return preparation, and disappears the moment a civil matter turns criminal. Where the facts are sensitive, an attorney can retain the accountant through the firm under what is called a Kovel arrangement, which brings that work within the full attorney-client privilege instead. The order matters, and it cannot be corrected after the fact.

In most circuits the Tax Court can no longer hear the case. The IRS assesses the tax and moves to collection. Options remain, including audit reconsideration, an offer based on doubt as to liability, or paying and suing for refund in district court, but the inexpensive path is gone. In most circuits the 90 days is treated as jurisdictional and cannot be extended.

It depends on the matter. Some engagements are handled on a flat fee, quoted in writing before work begins; others are better suited to hourly billing. Which structure fits your situation is worked out together on the first call, once the matter is understood. That first conversation, in which your deadline is identified and whether it is still open, costs nothing.