IRS Collection
The Treasury Secretary and IRS have made it clear that collection efforts will remain a core priority for the agency. Navigating collection actions can be incredibly complex for any taxpayer. alliantNational’s team, made up of experts with decades’ worth of experience, can help taxpayer individuals and businesses alike work through collection issues with the IRS in a succinct and productive manner.
The alliantNational team is made up of former IRS personnel who held key leadership positions. These include Steve Miller, the former Acting Commissioner of the IRS, Darren Guillot, the former Commissioner of the IRS Small Business/ Self-Employed Division and others, who work with a team of associates to ensure positive outcomes for our clients.
Darren Guillot
Director
Sarah Husbands
Senior Tax Attorney
NAVIGATING IRS COLLECTION ACTIVITIES
- Disputing Tax Liabilities Through the Collection Process
- Employment Taxes – Trust Fund Recovery Penalty (§ 6672)
- Notice of Federal Tax Lien (“NFTL”) Issues
- Sophisticated alternatives to the lien, that include collateral (such as mortgages and lines of credit in favor of the U.S., or bonds)
- Subordinations
- Discharges
- Withdrawals
- Certificates of Non-Attachment
- Payment Alternatives (In Lieu of Enforced Collection)
- In Business Installment Agreements
- Closely-Related Businesses with a Large Balance Due
- Partial Payment Installment agreements and Offers in Compromise
- Corporate Examinations Flow Through to Shareholders
- Non-Streamlined Installment Agreements
- Regular Repayment Options
- Complex Levies and Seizures
- Our expertise includes seeking the release of, or the proactive defense against:
- Levies of bank accounts
- Federal Payment Levy Program (“FPLP”) of federal contractors and Medicare providers
- Judicial Seizure – Personal Residences
- Seizure of real property (investment homes, office buildings, land, etc.)
- Seizure of personal property (cars, planes, boats, art, collectibles, etc.)
- Seizures of virtual currency, stock, and individual retirement accounts
- Our expertise includes seeking the release of, or the proactive defense against:
- IRS Passport Program §7345
- Suits for Injunctive Relief and to Reduce Liens to Judgment
- Revenue Officer/Office of Fraud Enforcement (OFE) Criminal Referrals
- Civil Penalty Disputes (Abatement, Reasonable Cause)
- OIC and FICA specialization for High Income Professionals
- Installment Agreements without financial disclosure for those Individuals owing up to $250,000
- High Income Delinquent Filer (“HiDeF”) Sweeps
- High Income High Balance Due Initiative
- Civil Penalty Disputes (Abatement, Reasonable Cause)
- Collection-Based Administrative Appeals
- State Tax Liability Issues
- Securing Refunds of Previously Disallowed Tax Credits
- Resolving Tax Liabilities Due To:
- Misapplication of Payments or Other IRS Error
- “Responsible Party” Issues under the Affordable Care Act
