A Practical Guide to Tax Representation for Chicago Taxpayers
If you are facing an IRS audit, wage levy, other tax levy or back taxes, compare tax law firms serving Chicago taxpayers by the issues they handle, the proposed representative and the scope of work. The right engagement depends on your facts and deadlines; hiring a firm does not guarantee a particular outcome.
A tax matter may involve transaction planning, return reporting, a civil examination, collection or possible criminal exposure. Identify the work you actually need before comparing a large practice and a smaller firm. Size alone does not establish expertise, availability or suitability for your case.
Federal tax questions can involve income reporting, digital assets or Employee Retention Credit claims. Illinois taxpayers may also have separate state and local tax obligations. The applicable rules depend on the taxpayer and transaction.
The right firm depends on your situation. Transaction planning and tax controversy involve different tasks, although a firm may handle both. If a levy or other deadline is approaching, ask who will review the notice promptly, what response is available and whether the firm is accepting the matter. Aggressive marketing is not a substitute for a legally supported response.
This guide covers credentials, representation scope, audits, collection alternatives, Illinois and local tax issues, and current reporting concerns. Read the actual notice and confirm the applicable procedure before relying on a general description or a directory ranking.
Evaluating Tax Representation for Chicago Matters
When comparing tax law firms serving Chicago taxpayers, start with the taxpayer, tax agency, issue and deadline. Ask about relevant experience, who will perform the work, how communication will be handled, and the fees and expenses. An office location or a directory listing does not by itself establish that a particular lawyer is authorized or available to handle your case.
If you consult Chambers USA or another directory, check the publication year, practice category, jurisdiction and the specific lawyer or practice being described. A ranking is not a substitute for checking licensing, relevant experience and engagement terms. This guide does not verify or assign a ranking to any firm, and a directory listing does not predict the result of an individual case.
Matching the Practice to the Tax Problem
Tax planning addresses how proposed transactions are reported and taxed; tax controversy addresses disputes, audits and collection. Look for experience in the specific issue and procedural stage involved. A representative handling a revenue officer matter may need to review financial records and collection alternatives, while a transaction may require a different analysis. Neither firm size nor a practice label establishes competence on its own.
Review the relevant notices, filing history, records, and deadlines before choosing a response. Evaluate professional assistance according to the facts, applicable law, and agreed scope of representation. Related resources: Internal Revenue Service.
Federal, Illinois and Local Representation
Federal IRS matters, Illinois Department of Revenue disputes and local property-tax assessments follow different procedures. For an Illinois notice, identify whether the available route is an IDOR administrative hearing, the Illinois Independent Tax Tribunal or another authorized procedure; jurisdiction and deadlines depend on the notice and tax involved. Local property-tax appeals have separate processes. Confirm licensing, any required admission and the proposed scope rather than assuming that Chicago ties or a physical office determine the outcome. See the official Illinois dispute options.
Services to Discuss with a Tax Attorney
Use the following questions to compare a proposed engagement. Large firms and smaller practices may offer overlapping services; ask about the actual team, relevant admissions, fees and exclusions instead of assuming that size determines the work a firm can handle.
| Service Type | What to Verify | Scope to Confirm |
|---|---|---|
| Audit Defense | Experience with the taxpayer, tax issue and examination stage | Document review, responses, meetings and appeal deadlines |
| Tax Litigation | Admission and experience in the court that has jurisdiction | Administrative proceedings versus separately retained court litigation |
| Debt Settlement | Eligibility analysis for a payment plan or offer in compromise | Applications, financial disclosure, continuing compliance and fees |
| Criminal Defense | Experience with criminal tax investigations and defense | Who provides legal advice and handles interviews or proceedings |
| Property Tax | Experience with the relevant county and property-assessment rules | Valuation evidence, filing windows and any later appeal |
IRS Audit Defense and Litigation
An IRS examination reviews the accuracy of a return and may result in no change, additional tax or other adjustments. Preserve records and evaluate the requested information and deadlines. A civil examination can raise possible fraud issues and lead to a criminal referral; the informal term “eggshell audit” describes a civil matter with potential criminal exposure. No representative can promise that an examination will not escalate.
For IRS audit representation, verify the proposed representative’s credentials and authority. Depending on the notice and procedural stage, a disagreement may be considered by IRS Appeals or a court with jurisdiction. U.S. Tax Court representation requires admission to that court; it is not automatic for every attorney. An LL.M. in Taxation may indicate additional study, but it does not replace current licensing, relevant experience or timely filing.
State and Local Tax (SALT) and Property Tax Appeals
Chicago taxpayers may face federal, Illinois and local tax obligations. Income, sales and use, withholding and property taxes can involve different agencies and procedures. An IRS resolution does not automatically resolve an Illinois or local liability, and a local property-assessment appeal is distinct from an IDOR tax dispute.
For a Cook County property-assessment issue, verify the property’s township, assessment year, valuation evidence and the applicable Assessor or Board of Review filing period. Later review has its own requirements. A sales-tax audit for a business is a different matter from an assessment appeal for an office building. Ask whether the proposed attorney handles the specific process; neither experience nor representation guarantees a reduction. Consult Illinois guidance on property assessment appeals and the Cook County Board of Review calendar.
Navigating IRS Enforcement and Debt Relief
An IRS levy legally takes property to satisfy a tax debt. The IRS generally must first assess the tax, demand payment and provide the required final levy notice and hearing opportunity at least 30 days before levy, subject to statutory exceptions. A qualifying final notice generally gives a 30-day period to request a Collection Due Process hearing; follow its stated deadline and submission instructions. Calling the IRS or hiring counsel does not itself submit that request. See tax levy relief; a release or return of funds depends on the applicable grounds and procedures, not a guarantee.
Responding to Levies and Wage Garnishments
The IRS can generally levy wages administratively without first obtaining a court judgment, subject to required procedures and exemptions. A wage levy is ordinarily continuous until released or otherwise satisfied, and part of the wages may be exempt under the applicable rules. A bank levy generally reaches funds held when the bank receives it, rather than later deposits. The bank normally holds the affected funds for 21 days before sending them to the IRS, so contact the IRS promptly about payment, an error or grounds for release.
A representative can request a levy release and present applicable hardship or payment-agreement grounds. Eligibility, documentation and timing depend on the law and case facts. Release does not cancel the underlying debt or necessarily remove a federal tax lien. Related guidance: wage levy release, federal tax lien remedies.
Settlement Options: Offer in Compromise and Abatements
Federal collection alternatives can include payment agreements, an offer in compromise or temporary collection deferral when their requirements are met. “Fresh Start” is not a single application or a promise of debt forgiveness. Compare the current rules, required financial information, filing compliance and total costs before choosing an option.
- IRS Offer in Compromise: An accepted offer may resolve an eligible tax debt for less than the full balance. Possible grounds include doubt as to liability, doubt as to collectibility and effective tax administration. Reasonable collection potential is central to a collectibility analysis, but it is not the sole basis for every offer. Forms, financial requirements and continuing compliance depend on the offer type; acceptance is not guaranteed.
- IRS penalty abatement: Depending on the penalty, relief may be available for reasonable cause, an administrative waiver or a statutory exception. A serious illness or disaster may be relevant, but the facts must support the applicable requirements. Penalties differ in their calculation and limits; there is no fixed percentage of every total tax bill. Removing a penalty does not automatically remove the underlying tax or all interest.
- Innocent Spouse Relief: Relief from joint-return liability can involve innocent spouse relief, separation of liability or equitable relief, each with distinct requirements. Lack of knowledge alone does not establish eligibility, and some equitable-relief cases concern tax reported but unpaid. Review the facts, filing deadlines and Form 8857 instructions; a spouse’s error or divorce does not automatically erase joint liability.
- Currently Not Collectible (CNC): If paying federal tax would prevent you from meeting basic, reasonable living expenses, request an IRS review of your financial circumstances. Currently Not Collectible status delays most collection; the debt remains due, interest and applicable penalties continue, refunds may be offset, and the IRS may still file a Notice of Federal Tax Lien. Eligibility and later review depend on the facts.
Reporting Developments Relevant to Chicago Taxpayers
Tax reporting can involve digital assets and Employee Retention Credit claims. The applicable federal rules and any separate Illinois or local obligations depend on the taxpayer and transaction.
Cryptocurrency and Digital Asset Compliance
Form 1099-DA reports digital asset proceeds from broker transactions. Reporting began for covered transactions occurring in 2025, with statements furnished in 2026. Taxpayers must report taxable digital asset transactions even when they do not receive this form; the reporting rules and basis requirements depend on the year and transaction.
Foreign account reporting depends on the account, assets and applicable thresholds. Under FinCEN Notice 2020-2, a foreign account holding only virtual currency is not currently FBAR-reportable; an account holding other reportable assets may be. Form 8938 is a separate analysis. Related guidance: More info about cryptocurrency tax liability, More info about voluntary disclosure.
Energy-Credit Changes and ERC Claims
The IRS continues reviewing Employee Retention Credit claims. A business receiving an examination, disallowance or repayment notice should review the stated basis, supporting records and response deadline.
Clean-energy credit rules have changed since the Inflation Reduction Act. Public Law 119-21, enacted in 2025, accelerated termination or changed conditions for several credits. For example, the residential clean energy credit is not allowed for expenditures made after December 31, 2025, with special rules determining when an expenditure is treated as made. Check the specific credit, installation or acquisition date, and current instructions rather than assuming an older incentive remains available. These questions are separate from ongoing payroll tax obligations.
Key Considerations for Selecting Chicago Tax Law Firms
Choose among tax law firms serving Chicago taxpayers after reviewing the matter’s urgency, the proposed lawyer’s role and the engagement terms. Ask who will communicate with you, what services are excluded, and how fees and third-party costs are handled. Potential criminal exposure requires particular attention to qualified legal advice.
Credentials and Professional Experience
Verify the lawyer’s active license, disciplinary information and experience with the particular issue. A JD, CPA credential, tax LL.M. or former government employment may be relevant, but none alone establishes suitability or special access to the IRS. For Illinois licensing information, use the ARDC Lawyer Search. Check U.S. Tax Court admission if that forum is involved; IRS administrative representation and court admission are different. No credential guarantees favorable treatment of a settlement proposal. Related guidance: help with back taxes.
Success Rates and Client Testimonials
Treat success rates, testimonials and directory honors as claims to examine. Ask which matters, time periods and outcomes a statistic covers and whether it is comparable to your situation. A past result or professional recognition does not guarantee a result for you. Confirm who would actually handle the case rather than relying solely on a firm-wide accolade.
Review the relevant facts, documents, filing requirements, and deadlines before choosing a response. Confirm professional qualifications and the agreed scope of assistance; outcomes depend on the applicable law and circumstances. Related resources: More info about international tax services.
Frequently Asked Questions about Chicago Tax Law
Can I be criminally charged for unpaid taxes in Illinois?
Unpaid tax does not by itself establish a criminal offense. Federal offenses can involve willful evasion, willful failure to file or pay, or willful failure to collect, account for and pay over certain taxes; the required elements differ by offense. Illinois law also provides criminal penalties for specified willful or fraudulent tax conduct. Withholding and other collected-tax obligations deserve prompt review, but this article does not quantify a higher investigation risk for Chicago businesses. Seek qualified counsel if intentional conduct or an investigation may be involved.
What is the difference between a civil tax audit and a criminal investigation?
A civil audit determines the correct tax and may involve additional tax, interest or civil penalties. A criminal investigation examines suspected violations that may lead to prosecution; an investigation or referral is not a conviction. Civil findings can prompt a referral to IRS Criminal Investigation when potential criminal conduct is identified. If that risk exists, obtain legal advice about responding truthfully, preserving records and protecting applicable rights; do not assume routine audit representation includes criminal defense.
Do I need a tax attorney for an IRS audit or can a CPA handle it?
Attorneys, CPAs and enrolled agents generally have broad representation rights before the IRS, subject to eligibility and practice rules. A CPA can handle more than return preparation or arithmetic errors; the right representative depends on the issue and experience. Court representation has separate admission requirements. Under Internal Revenue Code section 7525, certain confidential tax-advice communications with federally authorized tax practitioners may receive protection in specified noncriminal federal tax matters, but that statutory protection does not extend to criminal tax matters. Attorney-client privilege is also not absolute: ordinary return-preparation information is not automatically protected, and communications furthering a crime or fraud are excluded. Seek advice on the particular communication and proceeding rather than assuming every discussion with a lawyer or accountant is privileged.
Conclusion
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.
Contact Segal, Cohen & Landis about a Chicago tax matter to discuss a consultation and the available scope of assistance. Confirm the proposed representative, meeting arrangements and fees before relying on any location or service description.
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.