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Civil Tax Defense 

Since 1978, over 60 years of combined experience with state and federal tax controversy work, defending against both assessment and collection of taxes.

Whether your civil tax problem concerns an IRS or state tax notice, failure to file returns, lien, levy, seizure of property, Tax Court case, DOJ suit to reduce to judgment in federal court and foreclose on real property, court of appeals, administrative appeal, or income tax audit, employment tax audit, pension plan/Form 5500 audit, or excise tax, we can assist you in considering your viable options and developing the best strategy.

Because of our holistic approach, we do not myopically focus on only the particular IRS notice or action of immediate concern, but look behind such issues to the underlying causes. This allows us to offer creative solutions resulting in lower overall settlement and improved financial health once settlement is obtained.

Successful options have included: improper assessment, audit reconsideration, Installment Agreement (IA) including Fresh Start (72-month Installment Agreement for balances under $50,000 and 84-month Installment Agreement for balances under $100,000), Partial Pay Installment Agreement, 72-month full-pay Installment Agreement, Offer in Compromise (OIC) including Offer in Compromise - Doubt as to Collectibility (OIC-DATC), Offer in Compromise - Doubt as to Collectibility - Special Circumstances (OIC-DATC-SC), Offer in Compromise - Effective Tax Administration (OIC-ETA), Offer in Compromise - Doubt as to Liability (OIC-DATL), expiration of the collection statute of limitations (CSED), currently not collectible (CNC), bankruptcy, pay or borrow and pay, or a combination of these.

Whatever your unique circumstances, there is almost always a good solution. Please review a sample of our Success Stories

Brothers Nathan and Scott MacPherson Provide an overview of Civil Tax Defense
Second-Generation Tax Defense Attorneys

Watch Mac’s sons Nathan and Scott MacPherson describe the firm’s Civil Tax Defense practice area. In the video, they describe the two main components of civil tax cases: assessment and collection, and outline the various collection alternative such as Offer in Compromise, Currently Not Collectible status, and Installment Agreement. They also touch on other issues such as Tax Court litigation, eggshell audits, trusts, and DOJ lawsuits in federal court.


Contact us now if you have received a lien or levy notice or other harassment from IRS. Click to learn about the Criminal Tax Defense and Holistic Tax Solutions practice areas and for more videos by the MacPhersons.

Offshore / Foreign Issues

Many of our clients reside outside of the United States and have complex currency, foreign company ownership, and offshore investment issues. Other clients own foreign bank accounts, real estate, or businesses, and have run afoul of FBAR and FATCA reporting requirements, such as filing FinCEN FBAR (Foreign Bank Account Report) 114, IRS Form 3520-A (Annual Information Return of Foreign Trust With a U.S. Owner), IRS Form 5471 (Information Return of U.S. Persons With Respect to Certain Foreign Corporations), IRS Form 8621 (Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund), IRS Form 8865 (Return of U.S. Persons With Respect to Certain Foreign Partnerships), or IRS Form 8938 (Statement of Specified Foreign Financial Assets).

Our global experience – Nathan has traveled to 25 countries (lived and worked in four), speaks four languages, and is licensed on two continents – allows us to better advise clients with offshore/foreign issues. We have helped clients utilize the Offshore Voluntary Disclosure Program (OVDP) to successfully reduce liability.

Further, if you have “invested” money offshore, or are involved in a tax shelter (what IRS calls an “abusive tax shelter”), you need to know how the IRS proceeds in such cases and what options may be available to you. We are experienced representing clients in both areas.

Cryptocurrency Issues

As announced in IRS Notice 2014-21, for federal taxation purposes, IRS does not consider "virtual currency" (such as Bitcoin, Ether, and LiteCoin) to be currency but rather treats it as property. This means that every time cryptocurrency is bought or sold – and every time someone makes a purchase of goods or services using cryptocurrency – a taxable event occurs (either a capital gain or loss) according to IRS.

Additionally, when someone successfully "mines" virtual currency, the person is required to report as income, on the date the cryptocurrency is received, the fair market value of the newly mined coins.

In July 2018 IRS announced a Virtual Currency Compliance Campaign and in July 2019 IRS began sending letters (Letter 6173, Letter 6174, or Letter 6174-A) to over 10,000 taxpayers – the names of whom were obtained through ongoing compliance efforts – warning them to report cryptocurrency transactions as capital gains and losses and file amended returns and pay back taxes if they had failed to do so originally.


Although IRS states it is not contemplating a virtual currency voluntary disclosure program, we have successfully worked with cryptocurrency exchanges, miners, and end users to keep them safe. Contact us immediately if you are contacted by IRS about your Bitcoin, LiteCoin, or other cryptocurrency.

We are experienced at handling both civil and criminal cases and often handle civil tax issues after resolving criminal cases. Some examples of areas of tax controversy include: 

  • Audits and appeals

  • Audit reconsideration

  • Jeopardy assessment

  • Suit to reduce tax assessment to judgment and foreclose on tax liens

  • Form 23C assessment issues

  • VEBA

  • Employee leasing

  • Tax shelters, e.g., Son of Boss

  • “hobby losses”

  • “infinite banking”

  • Domestic and foreign trust

  • FBAR, offshore initiatives/amnesty, and other foreign issues

  • Embezzlement income

  • Delinquent returns

  • Income and employment taxes / payroll taxes

  • 100% trust fund penalty

  • Abatement of tax, penalties, and interest

  • Tax liens and levies, including wage garnishments

  • Innocent spouse relief

  • Offers in compromise (OIC)

  • Installment agreements (IA)

  • Currently not collectible (CNC)

  • Collection due process hearings (CDP) and appeals to the U.S. Tax Court

  • Invalid assessment from faulty procedure or assessment officer without proper delegation order

  • Expiration of statute of limitations

  • Forfeiture

  • Issues of alter ego/nominee, successor liability, and fraudulent conveyance

  • Issues for individual and corporate clients of the Fifth Amendment right against self-incrimination in the face of the IRS summons or subpoena

  • Appearance in response to IRS administrative summons or subpoena

  • Summons litigation

  • Other tax litigation before the U.S. Tax Court, federal circuit courts, and the U.S. Supreme Court.

  • Bitcoin and other cryptocurrency issues.

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