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Tax Resolution Framework

We know what we do best. Sean Sadeghi offers you some of the best legal advice and counsel in Southern California when it comes to Tax Resolution, IRS Representation, IRS Audit and all other Tax Problem Resolution. I know that every case is unique and different, and will apply my in-depth, specialist knowledge to meet your exact needs. Simply put, protecting your rights is what I do best.

If you failed to file your tax returns, regardless of why – buried your head in the sand, figured you didn’t owe anything, were ill, or just didn’t feel like filing – we can help get you caught up.
We will prepare and file your delinquent returns. If you do not have the income information from the years you failed to file, don’t worry, we can usually get that information from the IRS.
We will prepare and file your delinquent returns. If you do not have the income information from the years you failed to file, don’t worry, we can usually get that information from the IRS.
Depending on how long it’s been since you filed, the IRS may have filed a “substitute for return” on your behalf. Basically, this means the IRS filed a tax return for you – and no, they did not allow you any deductions! If this is your situation,
We will work with the IRS to ensure the returns we prepare replace the substitute for returns the IRS prepared, taking in to account proper deductions, exemptions, and credits.
Whatever the situation, we will guide you through the complex rules and regulations to get you back into compliance with the IRS.
We  can secure tax information from the IRS, if needed, ensure you take advantage of all of available deductions, exemptions, and credits, and prepare and file your delinquent return.

Offer in Compromise

If you owe delinquent taxes, the worst thing you can do is to hope the IRS or state will forget about you. Don’t ignore those nasty notices that come in the mail; doing so can only make matters worse. The longer you wait to make arrangements to pay back your debt, the more you will owe in interest and penalties.

Sean can help you negotiate a payment plan or settlement with the IRS to get you current on your unpaid taxes. If you owe the IRS money, not only does the debt continue to grow due to interest or penalties, the IRS can also attach levies on your bank account, retirement account, and wages. In addition they can place liens on your property, which are public record and can affect your credit rating. Taking a proactive approach to resolve your unpaid tax debt, you will likely secure a more favorable outcome. Two of the primary approaches to resolution are:

  • Offer-In-Compromise (Negotiation of tax liability, paying less than you owe)

  • Installment Agreement / Payment Plan (Paying what you owe, but over time)

Before you start the process of negotiating a payment plan or settlement call TLC Tax Resolution.  TLC Tax Resolution will help you get any un-filed returns filed, assist you in choosing the payment or settlement option that is right for you, and work with you to negotiate with the IRS to resolve your unpaid tax debt.

Levies and Lien

Has the IRS seized your bank account or are they threatening to do so? Did you find a tax lien on your credit report? If so, call TLC Tax Resolution help. When you owe the IRS money and haven’t made arrangements to pay them, the IRS can seize or sell your property through the use of liens and levies.
Don’t confuse levies and liens. A lien is a claim on your property used to secure your tax debt. For example, the IRS could place a lien on your house and in the event of a sale or refinance any proceeds would go towards your tax debt. A levy, on the other hand, confiscates your property as a means to satisfy your tax debt. For example, the IRS will take all the money out of your bank account or attach your wages.
TLC Tax Resolution is experienced in negotiating with the IRS to secure the release of liens, the reduction or release of levies, and in the resolution of other IRS tax matters. Give us a call if you are at risk for or are being threatened by an IRS lien or levy.
TLC Tax Resolution will evaluate your situation, determine the best course of action, and negotiate with the IRS to secure a favorable resolution.

Audit Representation

Sean has represented several clients in IRS examinations. We are well versed in tax law and have the knowledge and experience to represent you effectively before the IRS. IRS examiners are often intimidating and will disregard your rights, given the opportunity. We know the rules and will make sure that the examination process is conducted in accordance with law.
During an examination, the IRS goes through your income and deductions and makes you prove that they are legitimate. The goal of this exercise, of course, is try and squeeze more tax dollars out of you. The burden of proof is on you. You have to verify your income, exclusions, exemptions, deductions, and credits. We hope you kept all those records and receipts!
TLC Tax Resolution tax professionals have represented countless clients in IRS examinations. We are well versed in tax law and have the knowledge and experience to represent you effectively before the IRS. IRS examiners are often intimidating and will disregard your rights, given the opportunity. We know the rules and will make sure that the examination process is conducted in accordance with law.
Sometimes, no matter how we try, it isn’t possible to reach a favorable, or even fair, resolution with the IRS. In these situations, one of our affiliate attorneys can take the matter to tax court. Our tax professionals will collaborate and use their cumulative experience to protect your rights and negotiate a favorable outcome to your examination.
TLC Tax Resolution will review the issues raised by the IRS along with your returns and supporting documentation to identify areas of concern, and represent you during the IRS examination to secure a favorable resolution.

Audit Reconsideration

TLC Tax Resolution will review your audit documents and determine if audit reconsideration is the right decision for you. If it is, we will represent you in the audit reconsideration process and do our best to secure a favorable outcome.
TLC Tax Resolution will review your audit documents and determine if audit reconsideration is the right decision for you. If it is, we will represent you in the audit reconsideration process and do our best to secure a favorable outcome.
During an examination, the IRS goes through your income and deductions and makes you prove that they are legitimate. The goal of this exercise, of course, is try and squeeze more tax dollars out of you. The burden of proof is on you. You have to verify your income, exclusions, exemptions, deductions, and credits. We hope you kept all those records and receipts!
TLC Tax Resolution tax professionals have represented countless clients in IRS examinations. We are well versed in tax law and have the knowledge and experience to represent you effectively before the IRS. IRS examiners are often intimidating and will disregard your rights, given the opportunity. We know the rules and will make sure that the examination process is conducted in accordance with law.
Sometimes, no matter how we try, it isn’t possible to reach a favorable, or even fair, resolution with the IRS. In these situations, one of our affiliate attorneys can take the matter to tax court. Our tax professionals will collaborate and use their cumulative experience to protect your rights and negotiate a favorable outcome to your examination.
TLC Tax Resolution will review the issues raised by the IRS along with your returns and supporting documentation to identify areas of concern, and represent you during the IRS examination to secure a favorable resolution.
During an examination, the IRS goes through your income and deductions and makes you prove that they are legitimate. The goal of this exercise, of course, is try and squeeze more tax dollars out of you. The burden of proof is on you. You have to verify your income, exclusions, exemptions, deductions, and credits. We hope you kept all those records and receipts!
TLC Tax Resolution tax professionals have represented countless clients in IRS examinations. We are well versed in tax law and have the knowledge and experience to represent you effectively before the IRS. IRS examiners are often intimidating and will disregard your rights, given the opportunity. We know the rules and will make sure that the examination process is conducted in accordance with law.
Sometimes, no matter how we try, it isn’t possible to reach a favorable, or even fair, resolution with the IRS. In these situations, one of our affiliate attorneys can take the matter to tax court. Our tax professionals will collaborate and use their cumulative experience to protect your rights and negotiate a favorable outcome to your examination.
TLC Tax Resolution will review the issues raised by the IRS along with your returns and supporting documentation to identify areas of concern, and represent you during the IRS examination to secure a favorable resolution.
During an examination, the IRS goes through your income and deductions and makes you prove that they are legitimate. The goal of this exercise, of course, is try and squeeze more tax dollars out of you. The burden of proof is on you. You have to verify your income, exclusions, exemptions, deductions, and credits. We hope you kept all those records and receipts!
TLC Tax Resolution tax professionals have represented countless clients in IRS examinations. We are well versed in tax law and have the knowledge and experience to represent you effectively before the IRS. IRS examiners are often intimidating and will disregard your rights, given the opportunity. We know the rules and will make sure that the examination process is conducted in accordance with law.
Sometimes, no matter how we try, it isn’t possible to reach a favorable, or even fair, resolution with the IRS. In these situations, one of our affiliate attorneys can take the matter to tax court. Our tax professionals will collaborate and use their cumulative experience to protect your rights and negotiate a favorable outcome to your examination.
TLC Tax Resolution will review the issues raised by the IRS along with your returns and supporting documentation to identify areas of concern, and represent you during the IRS examination to secure a favorable resolution.

Appeals and Collection Due Process Hearings

It is possible to appeal IRS collection actions. If the IRS is trying to enforce collection action against you, you have options. The two primary options are through a Collection Due Process (CDP) Hearing and the Collection Appeals Program (CAP). The CDP is more complex and is an “after-the-fact” process—one you would use after a Notice of Federal Tax Lien or Final Notice of Intent to Levy have been received. CAP is available for a wider range of collection actions and is usually faster. CDP hearings that are lost can be taken to court; CAP, however, cannot be.

  1. Through appeals and CDP hearings IRS collection action can often be stopped. TLC Tax Resolution is experienced in successful IRS negotiations to secure settlements and favorable resolutions.

  2. TLC Tax Resolution will explain your options and rights, help you determine how to proceed, and represent you through the entire process.

Penalty Abatement

Each year, some taxpayers are assessed penalties for failure to file or pay their taxes on time, or accurately report their income, or any number of other reasons the IRS chooses. Some of the most common types of penalties are for late filing, late payment, accuracy issues, federal tax deposits, or fraud.
If you have had penalties assessed, we may be able to help. If you can establish reasonable cause, the IRS may abate the penalty.
Presenting a case for penalty abatement requires a well thought out argument backed by applicable tax code, regulations, and case law. TLC Tax Resolution has the experience to help you put the best case forth for penalty abatement.

Interest Abatement

The IRS is like any other government agency and sometimes they make mistakes. If the IRS errs or delays in notifying you of taxes or penalties due, and the delay causes substantial interest to accumulate, you may be entitled to interest abatement.
Only limited circumstances qualify for interest abatement and TLC Tax Resolution can determine if you qualify. And, if you do, we can file an abatement request on your behalf.

Employment Tax issues and the Trust Fund Recover Penalty

If the IRS is investigating you for misfiled or un-filed employer tax returns or if you owe employment taxes and related penalties, TLC Tax Resolution can help you. There are a multitude of reasons why you could get into trouble with employer taxes; anything from bookkeeper error, cash crunch, employee theft, etc. Whatever the reason, the IRS takes employer tax issues very seriously – so expect them to come with a vengeance.
Employers are responsible for the calculation and withholding of a number of federal, state, and local taxes, including Federal Income Tax, Social Security Tax (FICA), Medicare Tax, and Federal Unemployment Tax (FUTA). This responsibility requires the timely deposit of both the employees’ FICA and Medicare taxes and the employer’s matching share.
TLC Tax Resolution will provide expert advice on employment tax matters and assist you in the resolution of employment tax issues related to missed or incorrect filings and unpaid tax deposits. We will then help to ensure that future returns and deposits are filed accurately and timely.

Innocent Spouse Relief

Many spouses innocently sign tax returns without a second thought. Like it or not, for better or worse, does include your tax liability if you file a joint tax return.  The path to being granted innocent spouse relief is not a simple one; it can be complicated and stressful, bringing up old wounds in many cases.
Should your spouse or former spouse find himself or herself in trouble with the IRS, you too may be in trouble. Divorce does not automatically relieve you of your tax debt incurred while married. If, however, you were unaware of the tax issues, you may be entitled to innocent spouse relief. If you qualify you will be relieved of your tax debt and your spouse or ex-spouse will get stuck with the entire tax bill!
The path to being granted innocent spouse relief is not a simple one; it can be complicated and stressful, bringing up old wounds in many cases.
TLC Tax Resolution will evaluate your unique circumstances and explain your available options to ensure the best possible outcome. Once you have chosen an option we will file the necessary documents to get you the tax relief you deserve.

Statute of Limitations (SOL)

There are specific Statues of Limitations (SOL) that apply to your taxes. There are statutes of limitations on how long the IRS has to collect a tax debt, audit your tax return, and so forth. Knowing which statute of limitations applies to your specific situation is crucial to ensure the IRS isn’t violating your rights; for example, by trying to collect a tax debt for which the SOL has past.

The current SOL limitations are:

  • The 3-year SOL – There is a 3 year SOL for the IRS to audit you after filing your tax return. If they try and audit you after the expiration of the SOL.

  • The 6-year SOL – This SOL applies when a tax return has a substantial understatement of gross income (25%+). Again, if the IRS tries to audit you after the expiration of the SOL, they’ll be SOL.

  • The Indefinite Statute – This statute applies if you filed a false or fraudulent return, willfully attempted to evade tax, or failed to file a required return.

  • The 10-year SOL – The IRS only has 10 years to collect a tax debt, if they don’t collect within this time they are out of luck!

TLC Tax Resolution will help you determine which SOL applies in your situation, ensure the IRS is adhering to applicable SOLs, and represent you against the IRS in the event they aren’t.

Frivolous Tax Positions

Since its inception, various individuals, groups, and organizations have unsuccessfully challenged the legality of the income tax. In 2002 the IRS published a legal summary to debunk the most common false or frivolous arguments. The summary states: Filing a return and paying taxes is not voluntary; the meaning of “income” is not in doubt; the definition of basic terms such as “taxpayer” and “employees” is not in doubt; the 16th amendment instituting income tax was ratified; there are no legal flaws to invalidate the IRS or tax forms; and, there are no strategies that can be put in place to permanently avoid filing returns or paying taxes – unless you expatriate (giving up your U.S. citizenship or green-card) and that is another subject all together.
The IRS is not amused by these frivolous arguments and more than a few people have wound up behind bars for trying to advance them. Even if you get lucky and aren’t charged with a crime, making a frivolous argument could be costly. The IRS can impose a frivolous filing penalty of up to $5,000 for filing a frivolous return or taking a frivolous position.
If you got unwittingly caught up in one of these “frivolous” arguments thinking you could somehow get out of paying taxes, TLC Tax Resolution will help get you back in compliance before it is too late.
TLC Tax Resolution will evaluate your situation and formulate a plan to get you back in to compliance. We will then help implement that plan and negotiate a reconsideration of any associated penalties.

Alternative Minimum Tax Issues

AMT stands for the Alternative Minimum Tax, which is intended to ensure that high-income taxpayers pay at least a minimum amount of tax. Tax laws give preferential treatment to certain kinds of income and allow special deductions and credits for certain expenses; without the alternative minimum tax, high-income taxpayers could take advantage of these tax laws to save big on taxes. The alternative minimum tax attempts to ensure that if you benefit from these tax advantages, you will still pay at least a minimum amount of tax.
The alternative minimum tax is a separate tax computation that reduces the benefit of certain deductions and credits, thus, creating a tax liability for an individual who would otherwise pay little or no tax.
The effects of AMT can be financially disastrous. There are strategies that can be implemented to help avoid or reduce the effects of the AMT. TLC Tax Resolution understands the appropriate steps of implementing those strategies for you.
TLC Tax Resolution will evaluate your potential AMT liability and determine the best strategy to avoid or reduce the effects of the AMT. We will then help you develop tax strategies for future years to help try and avoid AMT.

Filing Delinquent Tax Returns

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