FAQ
In addition to the questions and answers provided below, our tax attorneys, from time to time, answer tax litigation and tax fraud questions on Avvo.com. If you would like to see those responses, please click here.
General
- When do I need a tax attorney or a tax lawyer?
- The person who contacted me from the IRS seems very nice. Maybe I should just deal with him myself rather than hire a tax attorney?
- Will the IRS agent be mad if I hire a tax lawyer to represent me?
- Do I need a tax attorney to represent me, rather than an accountant?
- What is a Tax Specialist?
- The IRS employee handling my case isn’t being reasonable. Can I get my case transferred to someone easier to deal with?
- Is the United States Tax Court part of the Internal Revenue Service?
- Who (or what) is the Taxpayer Advocate?
- What is the Office of Professional Responsibility (OPR)?
- What is a resale certificate?
- What is an AOD, or Action on Decision?
- What is the Internal Revenue Manual or IRM?
- What is the Difference Between an IRS Revenue Agent, and a Revenue Officer?
FBAR (Foreign Bank Account Reporting)
- What is an FBAR?
- What is an FBAR attorney?
- What is the difference between a “noisy voluntary disclosure” and a “soft or quiet voluntary disclosure”?
- What are the penalties for failing to file a Foreign Bank Account Report 90-22.1 (FBAR)?
- Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers Questionnaire
Tax Fraud and Criminal Tax Problems
- What is a tax fraud coordinator?
- What is the difference between criminal tax penalties and civil tax penalties?
- What is a Kovel accountant?
- What are SARs (Suspicious Activity Reports) and Why Do I Care?
- What is an IRS Criminal Investigation (CI) Special Agent?
Tax Debt
- I told the person from the IRS that I wanted to talk to a tax attorney before I answered any further questions. He said the I didn’t need an attorney. Do I?
- What is a Notice of Deficiency?
- What is a collection due process hearing?
- What is the difference between an IRS tax levy, and an IRS tax lien?
Offer in Compromise (OIC)
- What is an offer in compromise?
- Why would the IRS agree to take less money than you owe?
- How long will my offer in compromise take to complete?
Independent Contractors
- What is the 20 factor common law test set forth in IRS Revenue Ruling . 87-41, 1987-1 CB 298?
- Everybody in my business uses independent contractors - it doesn't seem fair that the IRS has singled us out for a payroll audit. Can a tax attorney help us?
Payroll Tax Problems
- Does the IRS treat different kinds of taxes differently?
- Can I be held personally responsible for my corporation's payroll taxes?


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