
What Specific IRS Tax Issues Can a Dallas Attorney Handle?
Facing an IRS audit or collection notice can be stressful. A qualified IRS tax attorney serving Dallas can review the issues, explain your rights and help you respond within the applicable deadlines. The appropriate response depends on your records, the notice and the stage of the case.
Depending on the engagement and the representative’s qualifications, an IRS tax attorney can help you:
- Resolve IRS Tax Problems: Handle issues like back taxes, unfiled returns, and disputes.
- Protect Your Rights: Explain and assert the protections in the Taxpayer Bill of Rights, including your rights to representation and to challenge the IRS’s position.
- Negotiate with the IRS: Work to achieve favorable settlements, installment plans, or offers in compromise.
- Provide Representation: Assist with audits and administrative appeals; court representation requires admission to the particular court.
- Address Collection Actions: Review wage and bank levies and federal tax liens, and request available relief when its requirements are met. Hiring counsel alone does not stop collection.
Before responding, identify the tax years, amounts and deadlines involved. Keep the notice and supporting documents, and distinguish a proposed adjustment from a bill for an assessed tax.
This guide covers federal tax representation for Dallas residents and businesses. Texas taxes have separate rules and procedures: the Texas Comptroller administers taxes including sales and franchise tax. An IRS payment plan or settlement does not resolve a Texas tax account.
Tax problems can involve several issues at once: a missing return, an examination, a disputed assessment or collection of an unpaid balance. Identify which issues are actually present before choosing a remedy; an audit response and a collection alternative serve different purposes.
Common issues to discuss with a qualified representative include:
- Back Taxes: Review outstanding balances from earlier years and the available ways to dispute or pay them.
- Unfiled Returns: Identify outstanding filing requirements and reconstruct accurate returns from available records. Filing remains important even when you cannot pay in full.
- IRS Audits: Review the items being examined, organize supporting documents and respond to the examiner’s requests.
- Tax Liens: Determine whether a federal tax lien has arisen or a public Notice of Federal Tax Lien has been filed, and which release, withdrawal or property-specific remedies may apply.
- Tax Levies: This includes addressing bank account levies and wage levies (garnishments).
- Wage Garnishment: A representative can assess the levy and request release where the facts support it. Timing depends on the circumstances and IRS review; no specific release deadline is guaranteed.
- Penalty Abatement: Review eligibility for penalty relief. Interest abatement has separate requirements; reducing a penalty also reduces related interest charged on that penalty.
- Spousal Relief: A joint federal income tax return generally creates joint and several liability. Innocent spouse relief, separation of liability and equitable relief have different requirements and deadlines; perceived unfairness alone does not establish eligibility.
- Payroll Tax Issues: Review federal employment tax filings and deposits, including Form 940 for federal unemployment tax and Form 941 for quarterly reporting of withheld income tax and Social Security and Medicare taxes.
- Trust Fund Recovery Penalty: An individual who was responsible for collecting, accounting for and paying over trust fund taxes and willfully failed to do so may face a personal penalty. Business ownership alone does not establish both elements.
Use the phone number and instructions on your IRS notice for the assigned matter. If you need in-person taxpayer assistance, check the official IRS office locator and appointment requirements. A taxpayer assistance visit is not a substitute for filing an appeal or court petition on time.
The Benefits of Hiring a Local Tax Professional
A Dallas resident can compare local and remote representatives. Relevant experience, eligibility to practice, availability and a clear engagement agreement matter more than proximity alone.
Discuss how the proposed professional would handle these parts of your matter:
- Communication: Agree on who will explain notices, track deadlines and keep you informed about developments.
- Negotiation: Ask how the representative evaluates available remedies and supports a request with the necessary financial and legal information.
- Attorney-Client Privilege: Attorney-client privilege may protect qualifying confidential communications seeking legal advice, subject to exceptions and waiver; it does not protect every discussion or underlying record.
- Procedure: Ask about experience with the particular audit, appeal or collection procedure involved, including its filing and response deadlines.
- Collection Relief: A representative can request a levy release or another collection alternative when supported by the facts. Neither hiring counsel nor requesting relief guarantees an immediate release.
- Financial Planning: Consider how a proposed response affects current expenses, future tax compliance and your ability to meet agreed payments.
Confirm whether the proposed engagement includes return preparation, IRS administrative proceedings, Texas tax issues or litigation; these are different services. Review the firm’s Tax Services and confirm the scope for your case.
Stopping Aggressive IRS Collection Actions
The IRS can collect unpaid taxes through liens, levies and property seizures, subject to applicable procedures. An IRS tax attorney serving Dallas can help you review the notice and respond promptly.
- Tax Lien: A Tax Lien is a legal claim securing a tax debt, not a seizure. Release of the lien and withdrawal of its public notice are different remedies. Discharge can remove a lien from particular property, while subordination changes priority; each has its own conditions.
- Tax Levy: A Tax Levy takes property or rights to property to collect a debt. Review notice and hearing rights promptly, along with any basis for release. A lien and a levy are not interchangeable.
- Wage Levy Relief: Request a release promptly if an IRS wage levy prevents payment of basic, reasonable living expenses. The IRS must release a levy when it determines that the statutory economic-hardship condition is met. Release does not cancel the debt. Read more about Wage Garnishment.
- Property Seizure: The IRS can seize and sell property under its collection authority, subject to legal protections and procedures. A representative can review the notice, available challenges and alternatives; no asset-protection outcome is guaranteed.
Your Guide to Resolving IRS Problems with an IRS Tax Attorney in Dallas
Start by separating disputes over the amount owed from problems paying a correct balance. Preserve appeal rights while evaluating payment options; requesting a payment arrangement does not replace a required response to an audit notice.
A case review typically involves these steps:
First, confirm the scope and cost of an initial consultation. During an investigation phase, a representative reviews your notices, returns and supporting records and, with appropriate authorization, obtains relevant IRS account information. IRS records may not contain all the evidence needed for your case.
Next, compare the available responses, their eligibility rules, costs and deadlines. Agree who will provide records, submit filings and monitor the matter. Keep copies of submissions and evidence of delivery.
The Process for Resolving Back Taxes with an IRS Tax Attorney in Dallas
If you owe Back Taxes, an IRS tax attorney serving Dallas can help you evaluate available responses and payment options.
If paying in full is not possible, an Installment Agreement may allow payments over time, subject to IRS approval and compliance requirements. Interest and applicable penalties generally continue. Levy restrictions usually apply while an agreement request is pending and during an approved agreement, with exceptions; an existing levy needs separate attention.
An IRS Offer in Compromise may settle a qualifying debt for less than the full balance. For an offer based on inability to pay, the IRS considers income, expenses, assets and collection potential. Required returns and payments must be current, and an open bankruptcy generally prevents eligibility. Acceptance is not guaranteed, and application costs and payment rules should be reviewed before filing.
If paying would prevent you from meeting basic living expenses, the IRS may grant Currently Not Collectible (CNC) status. This pauses most collection activity but does not forgive the debt. Penalties and interest continue, refunds may be applied to the balance, and the IRS may file a lien notice or resume collection if your finances improve.
Fresh Start refers to IRS collection-policy changes, not a separate application that guarantees forgiveness. Evaluate the current requirements for the actual remedy, such as an installment agreement, lien-notice withdrawal or offer in compromise. Background: IRS Fresh Start Program.
How Dallas Tax Attorneys Handle IRS Audits and Disputes
Read an audit notice carefully and follow its instructions. The IRS initially notifies taxpayers of an audit by mail. IRS Audit Representation can include reviewing records and responding through an authorized representative. Common formats include:
Correspondence Audits: The IRS requests documents by mail concerning specific items on a return. Answer the requested questions and keep copies of what you submit.
Office Audits: An interview takes place at an IRS office. Review the appointment letter and organize the records requested for the issues under examination.
Field Audits: An examination may take place at your home, business or representative’s office. Its scope depends on the case. A representative can help prepare records and communicate with the examiner, but you remain responsible for providing accurate information.
If you disagree with proposed findings, review the available manager conference, administrative appeal and court options. A timely request for IRS Appeals must follow the applicable instructions. Discussions with the IRS do not extend the deadline for a Tax Court petition.
Help with Unfiled Returns and Penalty Abatement
Unfiled returns and unpaid penalties can create additional financial problems. A qualified IRS tax attorney serving Dallas can help you review the filing requirements, notices and available responses.
If you have Unfiled Tax Returns, the IRS may prepare a substitute return that does not include all deductions or credits for which you qualify. Filing an accurate return may change the assessment, but a reduction is not guaranteed. Address Unfiled Tax Returns even when full payment is not currently possible.
Different penalties have different defenses and relief rules. An IRS Penalty Abatement request may rely on reasonable cause, an applicable exception or First Time Abate (FTA) when its requirements are met. FTA does not cover every penalty, and a request must address the particular assessment.
Interest relief has separate legal requirements. Reducing a penalty also reduces the interest attributable to that penalty, but reasonable cause for a penalty does not by itself eliminate interest on unpaid tax.
How to Choose the Right Dallas Tax Attorney
Choose a representative with relevant experience, clear communication and authorization for the work your case requires. Ask about similar matters and the proposed approach without treating past results as a promise of your outcome.
When you’re facing tax challenges, finding someone you can trust and communicate with openly is key to making an informed choice.
What to Look for in an IRS Tax Attorney in Dallas
When vetting professionals, look for specific qualifications and experience that demonstrate their ability to help you effectively.
Legal Education and License: A Juris Doctor (J.D.) describes legal education; a degree alone does not establish current authority to practice. Verify the attorney’s active license and disciplinary status with the relevant licensing authority.
IRS Representation: Eligible attorneys, certified public accountants and enrolled agents can represent taxpayers before the IRS, subject to authorization and professional-practice rules. Their authority before a court is a separate question.
Relevant Experience: Ask who will handle your matter, what experience that person has with the tax and procedure involved, and how work will be supervised. A firm’s aggregate years of practice do not establish the qualifications of the assigned representative.
Federal and Texas Authority: An eligible attorney in good standing with a U.S. state or other qualifying bar may practice before the IRS under federal rules; a Texas license is not the sole route to federal IRS representation. Texas legal work and appearances in Texas courts require appropriate state authority. U.S. Tax Court admission is separate and should be verified if Tax Court representation is proposed.
A levy or garnishment requires prompt review of the notice and available relief. Hiring counsel does not itself stop collection; release requirements and timing depend on the facts and applicable procedure.
Understanding the Typical Cost and Fee Structure
Request a written fee agreement covering the work included, expenses, billing and any separate charges for return preparation, appeals or litigation. Fees vary by scope and complexity. The article Average Costs of Hiring a Tax Attorney in Los Angeles is background reading, not a Dallas fee quote.
Typically, tax attorneys may charge in a few different ways:
- Flat Fees: Set prices for defined services, like preparing an Offer in Compromise.
- Hourly Rates: For more complex cases like extensive audits, attorneys might charge an hourly rate.
- Advance Payments or Retainers: Ask what an upfront payment covers, how it will be applied and what happens to any unused amount under the agreement and applicable rules.
Before retaining a professional, confirm the fee arrangement, expected expenses and any limits on the engagement in writing.
Making the Most of an Initial Consultation
An initial consultation can help you assess whether a professional is a good fit. Confirm in advance whether there is a fee, what the meeting includes and whether any follow-up advice or work will cost extra.
- Case Assessment: Bring the notices, tax years and relevant records so the professional can identify the issues and urgent deadlines.
- Understanding Options: Ask which responses may be available and what facts must be verified before recommending one.
- Questions to Ask: Confirm who will handle your case, their qualifications, how they communicate and whether state issues or litigation are included.
- Scope and Cost: An introductory meeting may be limited. Do not assume that a free consultation, if offered, includes a written legal opinion, return preparation or representation.
- Next Steps: Clarify which records are still needed and who will take any time-sensitive action. An initial consultation alone does not establish that a deadline has been protected.
Use the meeting to assess fit and clarify responsibilities before agreeing to further work.
When Your Case Goes to Court: The Role of a Tax Litigation Attorney
Some unresolved tax disputes may qualify for judicial review. A tax litigation attorney can assess jurisdiction, deadlines and evidence, and whether a court proceeding is appropriate. Taxpayers may represent themselves where court rules permit, but litigation has procedural demands beyond administrative negotiation.
Court representation requires familiarity with the applicable procedural and evidentiary rules and admission to that court. Confirm that the proposed attorney is eligible to appear and that litigation is included in the engagement.
There are a few different courts where tax disputes can be heard:
- U.S. Tax Court: A taxpayer can generally contest an income-tax deficiency before paying it by filing a timely petition after a notice of deficiency. The usual deadline is 90 days after the notice is mailed, or 150 days if it is addressed to a person outside the United States. Other Tax Court case types have different rules and deadlines.
- U.S. District Court: A federal tax refund suit generally requires payment of the disputed tax and a timely administrative refund claim first; divisible-tax exceptions may apply. Jurisdiction, waiting periods and filing deadlines must be satisfied. A jury may be available in a qualifying district-court refund suit.
- U.S. Court of Federal Claims: This court also hears qualifying federal tax refund suits, generally after payment and an administrative refund claim. Applicable jurisdictional and timing rules still apply. Trials are before a judge, not a jury.
Forum choice depends on the type of tax, the notice, payment history, available remedies and deadlines. Do not assume that every IRS decision can be challenged in any of these courts.
The following table compares an administrative appeal with Tax Court proceedings; refund suits in other federal courts follow separate rules.
| Feature | Administrative Appeals | Tax Court Litigation |
|---|---|---|
| Timing | Usually before litigation; Appeals may also consider settlement after a Tax Court petition | Requires a timely petition and a matter within Tax Court jurisdiction |
| Payment Required | Generally no prepayment for a proposed deficiency dispute | Generally no prepayment to contest a deficiency; other case types have their own rules |
| Forum | IRS Independent Office of Appeals | U.S. Tax Court |
| Formality | Less formal, negotiation-focused | Court procedures and evidence rules; small tax cases use simplified procedures |
| Decision Maker | IRS Appeals Officer | Tax Court judge; no jury |
| Precedent Setting | Administrative resolution, not a judicial precedent | Depends on the opinion and procedure; small tax case decisions are not precedent and cannot be appealed |
| Attorney Role | Negotiation, presentation of facts/law | Trial advocacy, legal arguments, evidence presentation |
A qualified litigation attorney can help assess the evidence, procedural risks and possible settlement. Representation does not guarantee a favorable judgment or prevent additional tax, interest or penalties.
Conclusion: Choose a Response That Fits Your Tax Matter
Unresolved tax balances can accrue interest and penalties, and missed deadlines can restrict available remedies. Review the notice promptly and identify the next required step.
For back taxes, audits or collection notices, a qualified IRS tax attorney serving Dallas can help evaluate the applicable federal rules and available responses. Verify who will do the work and what the engagement covers.
Contact Segal, Cohen & Landis (SCL) to discuss the tax matter, relevant notices and deadlines, and available response options. Confirm the qualifications of the proposed representative and the scope of the engagement.
A useful case plan identifies the records needed, the disputed issues, payment capacity and upcoming deadlines. Ask the proposed representative to explain the available approach and its limits.
Payment plans, offers in compromise and penalty relief address different problems and have separate eligibility rules. Lien and levy remedies also differ. None of these options should be treated as an automatic cancellation of debt or collection activity.
Act in time to preserve response, appeal and court rights. Confirm the specific deadline instead of assuming that ongoing negotiations will extend it.
To discuss possible assistance, request an initial consultation and confirm its cost, scope and the qualifications of the person who would represent you. Keep responding to required deadlines while you decide whether to engage counsel.
Keep copies of your notices and submissions, and follow through on any agreed filing and payment obligations.
Contact a Dallas Tax Attorney to discuss your tax matter and the services available for your circumstances. Confirm consultation terms and representation arrangements when scheduling.
Have questions about this topic? Talk to an IRS attorney today.
Segal, Cohen & Landis, P.C. — Beverly Hills. Serving clients nationwide.

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.
