1. IRS Attorney New York on Initial IRS Notices and Taxpayer Panic
Facing an aggressive IRS collection notice can trigger immense stress and lead to rash decisions.
However, understanding the notice and the available options is the first step toward a manageable solution.
An IRS attorney in New York can demystify the process and outline a clear path forward.
Understanding the IRS Notice
A notice from the IRS demanding immediate payment for a large sum, such as the $100,000 liability faced by a Brooklyn-based small business owner, represents a serious collection action.
These notices are often the culmination of unfiled returns or unpaid taxes over several years, compounded by penalties and interest.
The recipient may feel cornered, contemplating drastic measures like selling property or filing for bankruptcy.
It is a critical moment where professional guidance from an IRS attorney in New York becomes invaluable.
An experienced IRS attorney in New York understands that these notices, while intimidating, are the start of a negotiation process, not the end of the line.
2. IRS Attorney New York Exploring Resolution Programs
The IRS offers several structured programs designed to help taxpayers who cannot pay their full tax liability immediately.
These programs, known as Tax Resolution services, are not widely advertised but are powerful tools in the hands of a knowledgeable legal professional.
A qualified IRS attorney in New York can assess a taxpayer's financial situation to determine the most advantageous resolution strategy.
The Installment Agreement Pathway
For taxpayers with the ability to pay their tax debt over time, an Installment Agreement under Internal Revenue Code (IRC) § 6159 is a viable option.
This program allows taxpayers to make monthly payments for up to 72 months.
For example, a restaurant owner in Queens struggling after the pandemic might use an Installment Agreement to manage a $20,000 tax debt by making affordable monthly payments over several years, allowing the business to remain operational.
Engaging an IRS attorney in New York to negotiate the terms can ensure the payment plan is sustainable and halts aggressive collection actions like levies.
An IRS attorney in New York can also work to freeze or reduce ongoing penalties once an agreement is in place.
The Offer in Compromise Solution
A more dramatic solution is the Offer in Compromise (OIC) program, authorized by IRC § 7122. This program allows qualifying taxpayers to resolve their tax liability with the IRS for a lower amount than what they originally owed.
In the case of the Brooklyn business owner facing a $100,000 debt, an OIC was the optimal strategy. An IRS attorney in New York would meticulously analyze the business's assets, income, and expenses to demonstrate to the IRS that the taxpayer's reasonable collection potential was far less than the total liability.
Through a well-documented OIC application, it is possible to achieve a significant reduction, as seen in this case where the debt was settled for just $5,000, representing a 95% reduction of the original amount.
3. IRS Attorney New York Navigating Foreign Asset Disclosures
Tax issues are not limited to domestic income; undisclosed foreign financial accounts can lead to severe civil and even criminal penalties.
The IRS has specific programs to bring taxpayers into compliance, but navigating them requires specialized expertise.
An IRS attorney in New York with experience in international tax matters is essential for resolving these complex cases.
Addressing Fbar and International Tax Issues
Failing to file a Report of Foreign Bank and Financial Accounts (FBAR) can result in staggering penalties.
However, for taxpayers whose non-compliance was non-willful, the IRS offers programs like the Streamlined Filing Compliance Procedures (SFCP).
Using these procedures, a taxpayer can become compliant by paying a reduced penalty, often 5% of the highest aggregate account balance.
In other situations, an IRS attorney in New York could build a "reasonable cause" defense to have penalties completely abated, arguing that the taxpayer exercised ordinary business care and prudence but was nevertheless unable to file on time.
Given the complexities of proving non-willfulness, guidance from an IRS attorney in New York is crucial to avoid potentially ruinous financial consequences.
4. IRS Attorney New York Securing a Favorable Outcome
The ultimate goal of tax resolution is to achieve a final, affordable settlement that allows the taxpayer to move forward with a clean slate.
This outcome is rarely achieved without the strategic negotiation and procedural knowledge of a legal expert.
An IRS attorney in New York serves as both a shield and a negotiator, protecting the taxpayer while working toward the best possible resolution.
Finalizing the Settlement
For the Brooklyn business owner, the $5,000 settlement was life-changing.
This success was not accidental; it resulted from a carefully prepared financial disclosure and persuasive legal arguments presented to the IRS.
An IRS attorney in New York ensured all forms were correctly filed, all communications were handled professionally, and the client's financial hardship was proven according to the IRS's own internal standards.
Cases like this demonstrate that an initial tax notice is not a final judgment but an opening for resolution, a process best navigated with an IRS attorney in New York by your side.
Dealing with the IRS can be daunting, but you do not have to face it alone.
The tax resolution programs offered by the IRS, such as the Offer in Compromise and Installment Agreements, can provide a path to financial stability.
The attorneys at SJKP have experience navigating these complex processes and can help you understand your options.
If you have received a notice from the IRS or are struggling with tax debt, contact us for a consultation to see how we can assist you.
26 Feb, 2026
