Tax & financial.
IRS audits, Notices of Deficiency, liens and levies, offers in compromise, innocent-spouse relief, state tax disputes, securities-fraud and FINRA arbitration — tax and financial-dispute practice runs on rigid statutory deadlines where missing a date is often the case. We match you to a Utah, Idaho, or Wyoming attorney whose case history fits the specific notice you received and the specific kind of fight.
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Sub-specialties within this area.
IRS audits, deficiencies & Tax Court
Correspondence audits (CP2000 letters), office and field audits, 30-day letters with proposed assessment, and the 90-day Notice of Deficiency that opens U.S. Tax Court jurisdiction. Tax Court is the only venue where you can litigate without paying first — petitioning within 90 days of the notice is jurisdictional and not extendable. After that, refund-court venues (district court, Court of Federal Claims) require pay-then-litigate. Choice of venue affects burden of proof, jury availability, and procedural posture.
Collections — liens, levies, CDP, OIC, installment
Once a tax is assessed, IRS collections runs on a 10-year statute (with tolling for bankruptcy, OIC pendency, CDP hearings, and other suspensions). Collection Due Process (CDP) hearings — requested within 30 days of a Final Notice of Intent to Levy or Notice of Federal Tax Lien — toll collections and preserve Tax Court review. Offer in Compromise (OIC), installment agreements, Currently Not Collectible status, and innocent-spouse relief are the primary collection-alternative tools. Passport revocation kicks in at the seriously-delinquent threshold (currently around $62,000, indexed).
Innocent-spouse & injured-spouse relief
Joint-return liability is joint and several, but innocent-spouse relief under IRC § 6015 can remove a spouse's liability for the other spouse's understatement or underpayment. Three forms exist: traditional innocent-spouse (§ 6015(b)), separation-of-liability (§ 6015(c)), and equitable relief (§ 6015(f)). Filing deadlines vary — generally two years from first collection activity for (b) and (c), with more flexibility under (f). Injured-spouse relief (Form 8379) is the separate remedy when a refund is offset for the other spouse's separate pre-marital debt.
Payroll tax & trust-fund recovery penalty
Unpaid payroll taxes (the withheld employee portion) trigger the Trust Fund Recovery Penalty under IRC § 6672 — personal liability against any "responsible person" who "willfully" failed to pay over. Officers, signing-authority bookkeepers, and check-signing employees can all be assessed personally. The investigation centers on the Form 4180 interview, and TFRP assessment is one of the few IRS tax debts that cannot be discharged in bankruptcy and survives the entity dissolving.
State tax disputes (Utah, Idaho; Wyoming no individual income tax)
Utah State Tax Commission and Idaho State Tax Commission assessments — individual income, sales-and-use, corporate franchise, employment, and property-tax appeals — run on state-specific procedures and shorter deadlines than federal. Residency disputes (especially for high-net-worth filers claiming a move out of state), nexus issues for online sellers, sales-tax sourcing, and successor liability on asset purchases are the recurring fights. Wyoming has no individual income tax, but sales-and-use, severance, and property-tax disputes are common.
Securities fraud & FINRA arbitration
Investor claims against brokers, advisors, and broker-dealers for unsuitable investments, churning, unauthorized trading, failure to supervise, misrepresentation, and Ponzi-scheme exposure. Almost all customer-against-broker disputes are subject to mandatory FINRA arbitration — there is no court and no jury, and the panel decision is largely non-appealable. Federal 10b-5 claims have a 2-years-from-discovery / 5-years-from-violation limit under Sarbanes-Oxley; state blue-sky and FINRA's six-year eligibility rule run separately. Recovery sources include the broker-dealer's net capital, errors-and-omissions insurance, and in some cases SIPC.
FBAR, FATCA & offshore-account disclosure
U.S. persons with foreign financial accounts exceeding $10,000 aggregate at any point in the year must file an FBAR (FinCEN Form 114); non-willful FBAR penalties can reach $10,000 per violation and willful penalties the greater of $100,000 or 50% of the account balance. FATCA reporting on Form 8938 layers on for many filers. Voluntary disclosure programs (Streamlined Filing Compliance, Voluntary Disclosure Practice) offer reduced-penalty paths for non-willful and willful non-compliance, but the path matters and the wrong choice can be catastrophic.
Three steps to the right specialist.
Tell us what's happening
A careful AI conversation walks through the facts. The exact notice or letter and its date (every IRS letter has a number — CP2000, LT11, CP504, Letter 1058, Notice of Deficiency); tax years and approximate amount; whether returns are filed for all open years; collection actions in progress (lien, levy, garnishment); whether a Revenue Officer is assigned; joint-return posture and any innocent-spouse facts; any unfiled FBARs or offshore accounts; for securities matters, the broker, account type, and what was lost.
We identify the sub-specialty
Not just "tax problem" — IRS audit, Tax Court litigation, IRS collections, innocent-spouse relief, payroll-tax/TFRP, state tax dispute, FBAR/FATCA disclosure, securities/FINRA arbitration. A Tax Court litigator and an FBAR specialist and a FINRA arbitration lawyer are three different fits.
Warm introduction to the right firm
We match you to the firm whose case history fits your sub-type. You're introduced, not handed off. The firm knows about your situation before they call — and they know whether a 30-day CDP window, a 90-day Tax Court window, or a FINRA six-year eligibility limit is running.
What we'll ask about.
- The exact IRS or state notice and its date — every letter has a number, and the number drives the deadline. CP2000, 30-day letter, 90-day Notice of Deficiency, Final Notice of Intent to Levy, Notice of Federal Tax Lien each open different doors with different clocks.
- Whether tax returns are filed for all open years — the IRS will not entertain an OIC, installment agreement, or most collection alternatives until the taxpayer is "in compliance," meaning all required returns filed.
- Collection actions already in motion — lien filed, levy issued (wage / bank / Social Security), passport-revocation referral pending, business assets at risk. Active levies frequently need CDP hearing requests within 30 days to pause.
- Joint-return posture and any innocent-spouse facts — when did the issue arise, did the requesting spouse know or have reason to know, has there been a divorce or separation, has the other spouse been abusive.
- For payroll-tax matters: who had check-signing authority, who controlled which bills got paid, who knew the trust-fund portion wasn't being remitted. These are the Form 4180 questions that drive TFRP personal liability.
- For securities matters: the broker-dealer, the advisor's CRD number, account agreements (almost always include FINRA arbitration clauses), what was sold, dollar loss, and when the loss was discovered.
Deadlines to know.
Tax practice runs on jurisdictional deadlines where there are no extensions and no equitable arguments. A Notice of Deficiency (the 90-day letter, 150 if outside the U.S.) gives a hard 90 days to petition U.S. Tax Court — miss it and the assessment becomes final, you must pay first, and you litigate in district court or claims court for refund. A Final Notice of Intent to Levy or Notice of Federal Tax Lien opens a 30-day Collection Due Process window — the CDP request tolls collections, preserves Tax Court review of collection actions, and is the most-missed deadline more common than the Notice of Deficiency. Tax Court petitions can be filed by mail (timely mailing equals timely filing) but the 90 days is calendar, not business. Federal collection statute is 10 years from assessment with tolling for various events. Innocent-spouse traditional and separation-of-liability claims must be filed within two years of first collection activity; equitable relief is more flexible. FBAR has a six-year limitation for assessment by the government; voluntary disclosure timing matters because once the IRS opens an examination, the program may close. Securities fraud under federal 10b-5 runs two years from discovery, five years from violation; state blue-sky often parallels; FINRA has a separate six-year eligibility rule that is not a statute of limitations but a procedural bar. Passport-revocation referrals can be unwound but speed matters — a revocation in process becomes a travel emergency. For state tax appeals in Utah and Idaho, the protest window from an assessment is generally 30 days; missing it usually forfeits the administrative appeal.
What people ask.
Most IRS controversy work — audit defense, collections work, Tax Court litigation — is hourly with a retainer. Rates in Utah, Idaho, and Wyoming typically run $300–$500 for experienced tax attorneys. Some engagements (offer in compromise, innocent-spouse) are flat-fee in the $3,500–$10,000 range depending on complexity. Securities-fraud and FINRA arbitration cases are almost always contingency, 33–40%. There's no fee for talking to us or for the introduction.
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