Segal, Cohen & Landis

Beyond the Bill: Choosing a Tax Relief Attorney

Samuel Landis, Esq.Approx. 11 min readPublished: Last updated:
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Choosing a Tax Relief Attorney for an IRS Dispute

A tax relief attorney advises on federal and state tax disputes and possible debt solutions. Depending on the facts and applicable rules, an attorney can:

  • Request release or suspension of eligible collection actions, including wage and bank levies.
  • Evaluate an offer in compromise or a payment agreement; debt reduction is not guaranteed.
  • Represent you in IRS examinations and administrative appeals, subject to authorization and practice rules.
  • Help address unfiled returns and assess civil or criminal exposure; filing does not guarantee immunity.
  • Advise on confidential legal communications and the limits of attorney-client privilege.
  • Explain applicable tax rules and develop a strategy based on your finances and deadlines.

Ignoring notices can increase the risk of enforced collection. The IRS can levy certain assets without first obtaining a court judgment, subject to legal procedures and protections. Interest and applicable penalties can increase unpaid balances.

Attorneys, CPAs and enrolled agents who are eligible to practice may represent taxpayers before the IRS. Tax Court representation requires separate admission; taxpayers may represent themselves, and qualified nonattorneys can be admitted. Hiring a lawyer does not suspend deadlines or collections automatically.

At Segal, Cohen & Landis (SCL), the starting point is to examine your notices, records and objectives, then discuss the available options and the scope of any engagement. No particular settlement or outcome can be promised.

Related tax relief guides:

What Is a Tax Relief Attorney, and When Might You Need One?

A tax relief attorney is a licensed lawyer whose work includes tax disputes. The engagement may cover agency proceedings, collection alternatives or litigation. Confirm relevant experience, practice eligibility and, where needed, admission to the particular court.

Attorney-client privilege can protect confidential communications for legal advice, but exceptions and waiver rules apply; ordinary return preparation is not automatically protected. Certain advice from federally authorized tax practitioners may receive a limited privilege under section 7525 in noncriminal federal tax matters. That protection does not extend to criminal proceedings or all tax communications. See IRS guidance on privilege.

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Core Services

An engagement should specify which of the following services it covers:

  • Tax debt resolution: assess eligibility for an offer in compromise, a payment agreement or temporary hardship collection relief.
  • Audit defense: organize records, respond to authorized requests and challenge unsupported adjustments while protecting response and appeal deadlines.
  • Collection assistance: evaluate available levy relief, lien procedures and payment alternatives. Retaining counsel alone does not halt enforcement.
  • Tax planning: explain compliance obligations and lawful planning options based on the taxpayer’s circumstances.
  • Compliance: identify missing filings and records and consider appropriate corrective procedures, without promising penalty relief or immunity.

Read about tax resolution services in California and confirm which services your engagement includes.

Situations That Warrant Prompt Attention

Consider obtaining qualified advice when notices, deadlines or legal exposure make a matter difficult to manage:

  • An audit notice: read the requested items and response deadline, even if you believe the return is correct.
  • Tax debt you cannot manage: there is no universal dollar threshold for needing counsel. Complexity, hardship and enforcement risk matter as much as the balance.
  • A lien or levy: a lien is a legal claim securing a debt; a levy takes property. Wage levies can continue over successive pay periods. Relief depends on applicable conditions.
  • Several unfiled returns: determine filing obligations, available records and potential penalties or other exposure rather than ignoring the missing years.
  • Possible tax fraud or a criminal investigation: obtain advice from counsel experienced in criminal tax matters before choosing a disclosure or response strategy.

Early attention helps preserve procedural options. It does not ensure a reduction in tax, penalties or interest.

Evaluating IRS Tax Debt Relief

A representative can review your income, assets, expenses and compliance history, assess available options, prepare submissions and communicate with the IRS. The result depends on eligibility, evidence and the applicable procedure.

“Fresh Start” describes IRS initiatives, not a universal debt-forgiveness entitlement. Each current payment or compromise option has its own requirements; check the operative IRS guidance rather than relying on a marketing label.

Offer in Compromise (OIC)

An OIC may settle a liability for less than the balance owed. Doubt as to liability requires a genuine dispute about the tax’s existence or amount. Doubt as to collectibility concerns insufficient assets and income. Effective tax administration can apply when full collection is possible but would cause economic hardship or be unfair or inequitable in exceptional circumstances. See IRS Topic 204.

Eligibility and documentation depend on the offer type. For an offer based on ability to pay, required returns and estimated payments must be current; employers have deposit requirements, and an open bankruptcy generally disqualifies an applicant. Check the current IRS requirements. Approval is not guaranteed. Our offer in compromise guide explains the process.

Installment Agreements and Payment Plans

A payment agreement may spread payments over time. Available terms depend on the balance, agreement type, collection period and other conditions; a single repayment term does not apply to everyone. Review the IRS payment-plan options.

Review affordability, fees, ongoing filing and payment duties, and default consequences. Interest and applicable penalties generally continue until payment, though some penalty rates may be reduced. See what to do when you owe the IRS but cannot pay.

Currently Not Collectible (CNC) Status

If paying tax would prevent payment of basic living expenses, the IRS may temporarily delay most collection activity. CNC status does not cancel the debt or necessarily prevent a tax lien. See IRS hardship collection guidance.

The IRS may require financial evidence and later reassess ability to pay. Penalties and interest can continue, and refunds may be applied to the debt. Read our IRS tax debt resolution guide for context.

Penalty Relief

Some penalties may qualify for administrative relief or reasonable-cause relief. Eligibility differs by penalty and filing period. The IRS’s current administrative-relief guidance describes both first-time abatement and the 2026 transition to an automatic program for eligible periods; neither removes every penalty.

Reasonable cause depends on the facts and ordinary business care and prudence. Illness or disaster may matter, but an adviser’s failure generally does not excuse late filing or payment. Other penalties have different standards. Check the applicable reasonable-cause rules and supply evidence; relief is not assured.

Responding to IRS Enforcement and Disputes

An authorized representative can help interpret notices, prepare responses and protect procedural rights. Taxpayers must still supply accurate information and meet deadlines. Representation does not prevent all direct IRS contact or guarantee a negotiated outcome.

Liens, Levies and Wage Collection

IRS collection powers are subject to statutory procedures, notice and hearing requirements and exceptions. Read the particular notice promptly; an informal discussion does not preserve every appeal right.

  • Levies seize property to collect a debt. Release may be available, for example, for qualifying economic hardship or an erroneous levy. See IRS levy information and our levy release guide.
  • A federal tax lien generally arises after assessment, notice and demand, and failure to pay. The public Notice of Federal Tax Lien alerts other creditors; it does not create the underlying lien. Release, withdrawal, discharge and subordination are different remedies and do not all cancel the debt. See IRS lien guidance and legal assistance with liens.
  • A wage levy generally continues over successive payments, subject to an exempt amount, until released or otherwise ended under the rules. Promptly evaluate hardship and other available relief. Our wage levy guide explains the issues.

Counsel can assess urgent remedies, but cannot promise immediate release or reversal. Protect the hearing and court deadlines stated in notices.

Representation During an IRS Audit

An audit may require records, explanations and analysis of tax law. Agree on who will handle each request and what work is within the engagement.

A representative can prepare submissions, dispute incorrect findings and assess administrative appeal or court options. Court jurisdiction and filing deadlines require separate attention. No result is guaranteed. See our IRS audit defense guide.

Unfiled Returns and Compliance

Missing returns can lead to assessments based on IRS information, penalties and interest. Criminal exposure depends on the facts; an ordinary error does not automatically constitute a crime.

Counsel can help choose appropriate delinquent-filing or disclosure procedures. The IRS Criminal Investigation voluntary disclosure practice addresses qualifying willful violations, requires timely and complete cooperation, and does not guarantee immunity. A disclosure may be too late after an examination, investigation or specified third-party information. Different options apply to nonwillful conduct. See our back-tax guide.

Choosing a Reputable Tax Relief Attorney

Compare qualifications, scope, fees and communication practices. Be cautious about guaranteed reductions or promises made before a review of your finances. Our guide to finding a tax attorney offers a starting point.

Qualifications to Check

Ask about the professional’s actual authority and experience for your matter:

  • License and admission: verify active bar status and disciplinary history. Eligible attorneys generally may practice before the IRS regardless of the licensing state; state-law work and court proceedings may require other authority. See IRS credential guidance and Tax Court admission information.
  • Relevant experience: ask about work involving comparable procedures and issues. Years in practice or past results do not guarantee an outcome in your case.
  • Tax controversy focus: confirm experience with the specific agency, tax and procedural stage, rather than relying on a general marketing description.
  • Reputation: check current independent records and evaluate reviews critically. Do not assume a rating or claimed result has been verified merely because it appears in an advertisement.
  • Location and access: ask how meetings, document exchange and representation will work. Service in a city does not necessarily mean a staffed local office; confirm any location important to you.

Fees and Retainers

Fees depend on scope, complexity and billing arrangements. A lawyer may propose hourly billing or a flat fee for specified work. Ask which expenses and later stages are included.

Request a written agreement explaining scope, fees, any advance payment, billing and how additional work is authorized. Compare cost with the assistance needed; paying a fee does not buy a particular tax result.

Handling the Matter Yourself or Hiring Help

Taxpayers may handle many matters themselves and retain their procedural rights. Professional help can be useful for complexity, workload or legal exposure. Consider these differences without assuming either approach guarantees success:

Consideration Handling it yourself Hiring a tax relief attorney
Privilege Your own communications with the IRS are not privileged. Confidential legal advice may be protected; exceptions and waiver apply.
Negotiations You may present your position and request eligible relief. Counsel can develop and present a supported position; success is not guaranteed.
Time and workload You manage records, correspondence and deadlines. Counsel handles agreed tasks; your cooperation remains necessary.
Procedural rights You retain taxpayer rights and must protect deadlines. Counsel can help exercise rights; court admission and jurisdiction still matter.
Outcome Depends on facts, law and compliance. Also depends on facts, law and compliance; no guaranteed result.
Compliance You remain responsible for accurate filings and payments. Advice can help, but taxpayer responsibilities remain.

The Taxpayer Advocate Service is independent within the IRS and provides free help for qualifying hardship or unresolved problems. Private counsel offers a different engagement, not a substitute for every TAS service. Assistance from either does not itself extend statutory deadlines.

Frequently Asked Questions

These answers help frame the choice of assistance; specific advice depends on your facts.

How much debt requires an attorney?

There is no fixed minimum. Consider disputed liability, filing gaps, business obligations, deadlines, hardship and possible criminal exposure. A smaller balance may still involve difficult legal issues.

Can an attorney guarantee a debt reduction?

No. Eligibility, evidence and applicable law determine the available resolution. Treat guaranteed settlements or promised savings with caution, especially before a financial review.

How do tax attorneys and CPAs differ?

Both may assist with tax matters, but licensing, training, scope and privilege rules differ. Choose someone qualified for the work you need.

  • Attorneys can advise on legal disputes and criminal exposure. Confidential legal advice may be privileged, subject to exceptions and waiver. Tax Court representation requires admission to that court.
  • CPAs often handle accounting, returns and financial analysis; eligible CPAs can represent taxpayers before the IRS. Tax Court representation is possible only after separate admission, including through its qualified-nonattorney process. Limited federal tax-advice privilege is not equivalent to blanket attorney-client protection.

For threatened criminal proceedings or litigation, consider counsel experienced in those matters. For other tasks, an eligible CPA or enrolled agent may be appropriate; confirm the actual scope of services.

Next Steps

Gather your notices, returns, payment records and deadlines before choosing a response. Understanding the procedural stage helps identify realistic options.

A tax relief attorney can evaluate the law, communicate within the engagement and prepare a supported position. Relief remains conditional, and representation alone does not stop collection or eliminate debt.

Segal, Cohen & Landis can discuss your tax dispute and the services that may fit it. Confirm availability, scope and fees before retaining the firm.

Contact us to discuss your situation and identify the documents needed for an initial review.

Have questions about this topic? Talk to an IRS attorney today.

Segal, Cohen & Landis, P.C. — Beverly Hills. Serving clients nationwide.

Samuel Landis

Samuel Landis, Esq.

LL.M. (Tax) · Selected to Super Lawyers®

Sam Landis is a Beverly Hills IRS tax attorney specializing in IRS collection defense, audit representation, and international tax compliance for foreign nationals and US expats.

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