Practice Areas

TAX DEBT HELP

We help clients who owe IRS or California taxes for prior years, including those facing tax liens and levies. After a thorough review of our client’s financial information, we develop and propose a plan to the tax authorities. We have successfully negotiated Offers in Compromise, where the IRS agrees to accept less (sometimes far less) than the total amount due. We have negotiated Installment Payment Plans, securing reasonable monthly payments for our clients. In some cases, our clients have been designated “Not Currently Collectable”, where no payments are due for a period of time.

It is most effective to involve us early in the collection process. We help our clients understand, protect and assert their rights. We have been successful convincing the government not to levy on client bank accounts and other assets; we have also convinced the government to release levies after they were placed on our client’s accounts and forego filing liens. At the conclusion of matters we see that the tax liens are released.

TAX AUDITS AND ADMINISTRATIVE APPEALS

Often, through early involvement, we can limit the issues under examination and close the audit as efficiently as possible. We also represent clients in administrative appeals to reach a favorable settlement without the need for litigation.

TAX LITIGATION

Sometimes it is necessary to file a lawsuit against the IRS to protect a client’s rights. With our extensive trial experience, we effectively litigate tax matters when the issues cannot be resolved to our client’s satisfaction during the audit or administrative appeal.

CRIMINAL TAX DEFENSE

We represent clients in criminal tax investigations and prosecutions, both as targets and as witnesses.

FOREIGN BANK ACCOUNT REPORTING

We have helped clients resolve tax and reporting issues related to their offshore financial accounts. Our clients have been accepted in the Offshore Voluntary Disclosure Program (soon to end) where they have eliminated criminal exposure and paid reduced penalties for their failure to report foreign accounts and income. We have also helped clients with both the domestic and foreign Streamlined Filing Compliance Procedures which will continue to be available. We help our clients file the necessary information returns and corrected income tax returns.

INNOCENT SPOUSE RELIEF

We have successfully obtained relief from “joint and several liability” for tax obligations caused by former spouses. We also work closely with family law attorneys to ensure that tax matters are appropriately addressed during the dissolution and property settlement process.

PAYROLL TAX MATTERS

We are experienced assisting clients with investigations into the proper classification of workers as independent contractors or employees. We also represent individuals when the IRS or California Employment Development Department assert they are personally liable for their company’s failure to collect and pay over employees’ withholding taxes to the IRS and/or California. This “trust fund penalty” can be asserted against a “responsible person” even where that person did not receive a personal benefit from the company’s failure to deposit the withheld taxes.

Abkin Law LLP

1 Embarcadero Center
Suite 1020
San Francisco, CA 94111
T: 415-956-3280
F: 415-906-8896