Tax Collection Defense and Assistance

If an IRS revenue officer contacts you or if the IRS sends you a notice of federal tax lien, consider hiring a defense attorney knowledgeable in tax collection matters. Dan has litigated Collection Due Process cases in the United States Tax Court, worked along with the United States Department of Justice Tax Division on foreclosures and reducing federal tax liens to judgment, handled international collection matters, and litigated tax matters in bankruptcy court during his tenure with the government. Dan also helped train many IRS revenue officers in information collecting and issuing summonses. Dan’s prior government experience allows him to effectively represent clients on collection matters.

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Dan advises clients on the following collection and tax debts matters:

• Negotiating and obtaining installment agreements and offers in compromise

• Appealing IRS collection actions (e.g., levy  or the filing of tax liens) to the Independent Office of Appeals through Collection Due Process or the Collection Appeals Program

• Representing clients who have received an IRS collection summons seeking the production of documents or testimony

• Assisting individuals the IRS considers responsible parties in trust fund recovery penalty matters

• Preparing and negotiating claims for innocent spouse relief

• Counseling clients who are pondering bankruptcy to reduce their tax liabilities

• Advising clients with delinquent or unfiled tax returns or significant previously unreported income

Dan also provides advice on unique issues relating to international collection of taxes:

• Passport revocation under I.R.C. § 7345

• Government requests for writs ne exeat republica

• Government suits to collect FBAR penalties

• Appointments of a receiver to collect foreign assets

• Suits to repatriate property

• “Prevent departure orders” for nonresident taxpayers

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