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Tax Controversy and Disputes

Our firm specializes in all phases of federal and state tax controversy work. Typically, a taxpayer will file a return and years later receive a notice that their return is under audit. While this may be an extremely stressful event for the taxpayer, the IRS and state tax authorities give taxpayers many opportunities to dispute additional assessments. The IRS will send a 30-Day letter with the proposed deficiency, which gives the taxpayer an opportunity to protest the deficiency. If the taxpayer timely files a protest, the case is sent to appeals to resolve the dispute. If the taxpayer fails to protest the proposed deficiency, the IRS will send a Notice of Deficiency 90-Day Letter, which allows the taxpayer to file a petition with the United States Tax Court. If the taxpayer misses this deadline, the tax is assessed regardless of validity. If a Tax Court Petition is filed, the case is sent to appeals to attempt to resolve the dispute. If no agreement can been reached, the case moves forward to prepare for trial. Most of the time, the case is resolved with IRS Chief Counsel’s Office prior to litigation and a decision document is signed which determines the deficiency or overpayment. It is very important to hire a licensed experienced tax attorney as soon as possible in an audit or correspondence examination due to the number of deadlines and opportunities to settle disputes early, which can reduce stress and cost on the taxpayer. Our Atlanta Tax Attorneys are able to diligently and quickly research the issues, help the taxpayer gather necessary documentation and evidence to defend or support their claim, and most of the time, greatly reduce the tax and penalty assessment. Even if a taxpayer has missed their opportunity to dispute the tax through the normal channels discussed above, the taxpayer still has options to dispute and correct the tax. These options include:

  • Audit Reconsideration
  • Offer in Compromise Doubt as to Liability

If an additional amount of tax is assessed from an audit or the taxpayer was unable to pay the tax due when they filed their return, we are able to provide a vast array of options to deal with the tax debt. Once an amount is owed, the IRS typically will send a Notice and Demand for Payment within 60 days of assessment. Then the IRS will follow with a series of letters (CP14, CP501, CP503, CP504) requesting payment and threatening to levy (Notice of Intent to Levy). The most important letter is the CP90 or LT11 Final Notice of Intent to Levy. Again, this letter is so important because it provides the taxpayer an opportunity to appeal the collection action, gives the taxpayer time to work out an agreement, and prevents any actual levy action. Thus, it is highly important that a taxpayer seek counsel as soon as possible so they do not miss any statutory deadlines and we have an opportunity to resolve the matter prior to collection action. The first priority for our firm is to:

  • Avoid Bank Account Levies, Wage Garnishments, Social Security Levies, etc.
  • Avoid Tax Liens
  • Avoid Seizures of Assets including but not limited to 401Ks and Real Property

Our firm works diligently to find the best cost-effective solution based on the amount of tax owed and the taxpayer’s financial ability to pay. Some of these options include:

  • Abating Penalties (if possible based on individual circumstances of case)
  • Negotiating Payment Plans (72 month, 84 Month, or Partial Pay Installment Agreements)
  • Placing Taxpayer in Currently Non-Collectible Status
  • Seeking an Offer In Compromise Doubt as to Collectibility or Doubt as to Collectibility with Special Circumstances
  • Bankruptcy Filing (Chapter 7, Chapter 13, Chapter 11)
  • Innocent Spouse Relief

If you would like more information please contact us today at (404) 551-5838 for a free one hour consultation with Alyssa Maloof Whatley, Atlanta Tax and Bankruptcy Attorney.

I run a CPA firm and Alyssa has helped my clients that have IRS issues. Her expertise ends up giving the clients more favorable tax liability positions than they had before. She is enjoyable to work with and communicates clearly and to the point. I have learned a lot from her due to her immense tax resolution knowledge.
Alyssa Whatley helped us with a major tax issue that seemed impossible and she seemed to do it with ease. She helped us through a very difficult and hard time. Alyssa's work ethics and performance set a very high standard that we value. She works with strong intention and honesty. She represented us so well and gave us honest answers. She was careful and this made us know that she is trustworthy. We knew that she really wanted to help us and that is her heart for why she does what she does. Alyssa has an endearing confidence that gave us assurance and a calm knowing that she is very knowledgable and good at what she does! Alyssa always responded promptly to us and kept us very informed. She is definitely at the top of her game in her field! Thankful to have had her representing us! Lindy
Alyssa immediately impressed me with her competence. That was most important to me. How well will my attorney do their job for me? Alyssa knocked it out of the park for me. Her understanding of our overly complex Tax laws never ceased to amaze me. Alyssa seemed to know every trick in the book to achieve the best results. Alyssa analyzed my state of affairs and delivered better results than I had hoped for. Before meeting Alyssa, I was wary about whether my attorney would have _my_ best interest at heart? I did not expect a cheerful attorney; What a difference a smile makes when you're going through troubled waters. Alyssa deserves my highest recommendation. I just wish I could express my appreciation better. Job well done, Alyssa! Thank you! Anonymous
I contacted Alyssa after I was wrongfully imprisoned due to a clerical error by Fulton Co. Alyssa listened with empathy to my entire story and took all of the correct steps in handling my case. Alyssa updated me frequently on my case so that I could rest assure it was in the right hands. Alyssa was able to get my case dropped and my money returned very quickly. Mrs. Whatley came highly recommended to me and I see why. Alyssa's professionalism, experience, compassion, and positive attitude was exactly what I needed during this time of uncertainty. Kaitlin
Mrs.Whatley handled a case for us with the IRS. We had tax liens after a Chapter 13 bankruptcy and she was able to have them removed promptly. She is extremely knowledgeable about tax law and I'd recommend her to anyone, including my own family and friends. Keith