Articles Posted in Tax Controversy

When people Google “tax attorney vs. enrolled agent vs. CPA,” they are almost never curious in the abstract. Something has already happened. An IRS notice arrived in the mail. A Revenue Officer showed up. An EDD auditor sent a questionnaire. A Franchise Tax Board letter proposed an assessment. Payroll taxes fell behind. A client sold a business and the numbers don’t add up. In that moment, the last thing anyone needs is a three-way comparison chart written by someone who has never sat across from an Appeals Officer.

So let’s skip the textbook treatment. Here is an honest, practitioner’s view of what each of these three credentials actually does, where each one shines, where each one is overkill, and how our firm — Mike Habib, EA, based in Whittier, Los Angeles County, California — fits into that picture. We serve individuals and businesses in all 50 states and U.S. taxpayers living overseas, and we work on a flat-fee basis in most engagements. That second point matters more than most people realize, and we will come back to it.

The Short Answer, Before We Get Into the Weeds

All three credentials — Enrolled Agent (EA), Certified Public Accountant (CPA), and tax lawyer — can represent you before the IRS. That is where the similarities largely end. CPAs are accountants first, with some tax specialists among them. Tax attorneys (board-certified) are lawyers whose superpower is litigation, legal privilege, and complex legal questions. Enrolled Agents are the only federally licensed practitioners whose credential exists solely to represent taxpayers before the IRS. We do taxes. That is the entire job.

For most tax problems — audits, collections, unfiled returns, payroll tax disputes, offers in compromise, installment agreements, penalty abatements, EDD and FTB matters, multi-state issues, expat returns — an experienced EA firm is usually the right call. For criminal tax matters, Tax Court litigation, or complex legal structuring, a tax attorney is appropriate. For a full-scope financial audit of your company’s books, a CPA firm is appropriate.

Our firm handles the first category. We refer the second and third when they’re genuinely needed — and we’ll tell you honestly when they’re not.

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In the intricate world of tax compliance and planning, businesses and individuals often encounter complex transactions that require specialized expertise to navigate. Whether it’s a corporate restructuring, a high-stakes merger, or a sophisticated investment strategy, the tax implications of these transactions can be daunting. One of the most critical tools in ensuring compliance and mitigating risk is the tax opinion letter. This document serves as a professional analysis of the tax consequences of a specific transaction, providing clarity and protection for taxpayers. For those in need of expert guidance, the Los Angeles-based tax firm of Mike Habib, EA, stands out as a trusted partner in navigating these challenges.

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Navigating the IRS appeals process can be daunting, but understanding the steps involved and knowing how to effectively present your case can significantly improve your chances of a favorable outcome. This comprehensive guide will walk you through the IRS appeals process, detailing each step and explaining how our representation tax firm can assist you.

Table of Contents
Introduction to the IRS Appeals Process
When to Consider an Appeal
Steps to Appeal an IRS Decision
Step 1: Understand Your Appeal Rights
Step 2: Prepare Your Case
Step 3: File a Protest or Small Case Request
Step 4: Attend the Appeals Conference
Step 5: Await the Decision
Types of Appeals
Collection Appeals
Examination Appeals
Penalty Appeals
How Our Representation Tax Firm Can Assist

Get tax appeal help today by calling us at 1-877-788-2937.

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Navigating the complex world of taxes can be a daunting task, especially when dealing with various government agencies such as the IRS, FTB, CDTFA, BOE, and EDD. For taxpayers seeking help in Huntington Beach, CA, understanding the intricacies of tax compliance and finding the necessary support can alleviate the stress that often accompanies tax season. In this article, we will explore the different agencies involved in tax matters and highlight the resources available in Huntington Beach to help individuals and businesses with IRS, FTB, CDTFA, BOE, and EDD-related tax issues.

For professional tax representation help call us at 1-877-788-2937.

Santa Ana – Anaheim – Irvine – Garden Grove – Costa Mesa- Mission Viejo – Westminster – Fullerton – OC Orange County, California

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CLIENT LETTER EXPLAINS RECENT DEVELOPMENTS THAT MAY AFFECT YOUR TAX SITUATION

Dear Clients:

The following is a summary of important tax developments that have occurred in the first three months of 2018 that may affect you, your family, your investments, and your livelihood. Please call us for more information about any of these developments and what steps you should implement to take advantage of favorable developments and to minimize the impact of those that are unfavorable.

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Employment Taxes and the Trust Fund Recovery Penalty (TFRP).

Notice 784, Could You be Personally Liable for Certain Unpaid Federal Taxes?

IRS has updated its webpage guidance on the trust fund recovery penalty and who IRS can reach to pay it. The guidance is a reminder for all potential “responsible persons” to make sure that timely payment of employment taxes is given the highest priority at any profit or nonprofit enterprise.

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IRS Small Business/Self-Employed Division memorandum, Calculation of Reasonable Collection Potential in Certain Offers in Compromise Cases (Apr. 28, 2016)

IRS’s Small Business/Self-Employed Division (SB/SE) has instructed its Collection employees not to reject offers in compromise (OICs) by persons in the Cannabis / marijuana business, in states where marijuana sales are legal, merely on public policy grounds.

Offer in Compromise— OICs. Code Sec. 7122(a) authorizes IRS to compromise a taxpayer’s income tax liability. Code Sec. 7122(d)(1) gives IRS wide discretion to accept compromise offers and to prescribe guidelines “to determine whether an offer-in-compromise is adequate and should be accepted.” IRS will consider an OIC where: (1) the taxpayer is unable to pay the tax; (2) there is doubt as to the taxpayer’s liability for the tax; or (3) a compromise would promote effective tax administration because collection of the full amount of tax would cause economic hardship for the taxpayer, or compelling public policy or equity considerations provide a sufficient basis for compromising the liability. (Reg. § 301.7122-1(b)) There is doubt as to collectibility “in any case where the taxpayer’s assets and income are less than the full amount of the liability.” (Reg. § 301.7122-1(b)(2))

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Chicago, IL Taxpayer Rights Power of Attorney – Representing individuals and businesses before the IRS

If you are facing a tax audit, IRS tax levy to back tax help to unfiled tax returns and more, the Chicago tax attorney is here for your need. The qualified tax lawyer can handle all legal matters related to taxes as well as assist businesses when it comes to properly filling out their tax forms. Here is a sampling of the services provided by the Chicago tax lawyer. Did you receive an IRS or state tax lien notice, letter, postcard or phone call?

  • Back Tax Help
  • Innocent Spouse Tax Relief
  • IRS Help
  • IRS Tax Audit Representation
  • Tax Debt Settlement
  • Tax Negotiations & Resolution
  • IRS tax levy and lien release Help
  • Penalty Abatement
  • 941 Payroll Tax Problem Help & More

Get reliable IRS representation, call 877-788-2937.

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Phoenix, AZ Taxpayer Rights Power of Attorney – Representing individuals and businesses before the IRS

For those living in the greater Phoenix, AZ area, finding the right tax attorney serving Phoenix can mean all the difference when it comes to individuals and business owners. The tax lawyer is available to take on cases that range from the proper filling out of forms to representation in tax court when facing the IRS. In addition, the Phoenix tax attorney offers the following services;

  • Back Tax Help
  • Innocent Spouse Tax Relief
  • IRS Help
  • IRS Tax Audit Representation
  • Tax Debt Settlement
  • Tax Negotiations & Resolution
  • Payroll 941 Tax Problem Help
  • Unfiled Tax Returns
  • Wage Garnishment Release & More

Did you receive an IRS or state tax lien notice, letter, postcard or phone call?

Get reliable IRS tax representation in Phoenix, please contact 877-788-2937 today.

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Atlanta, GA Taxpayer Rights Power of Attorney – Representing individuals and businesses before the IRS

In the greater Atlanta, GA area, there are a number of highly qualified tax attorneys who can help you with all the legal matters related to your tax returns. From filling out the forms to helping you with an IRS audit or IRS tax levy, the trained tax lawyer is here to help you. Some of the services provided by the Atlanta tax attorney includes, but is not limited to the following;

  • Back Tax Help
  • Innocent Spouse Tax Relief
  • IRS Help
  • IRS Tax Audit Representation
  • Tax Debt Settlement
  • Tax Negotiations & Resolution
  • Payroll Tax Problem Help
  • Penalty Abatement
  • 941 Payroll Tax Problem Help & More

Did you receive an IRS or state tax lien notice, letter, postcard or phone call?

Get expert tax representation today by calling Mike Habib at 877-788-2937

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