Segal, Cohen & Landis, P.C.
Manhattan IRS Tax Attorney
Serving Manhattan from our Beverly Hills office. Most matters are handled entirely by phone and video.
Manhattan taxpayers operate inside the most aggressive tax enforcement triangle in the country: the IRS, the New York State Department of Taxation and Finance, and the New York City Department of Finance, each auditing independently and each capable of issuing its own assessment, lien, and levy. For Wall Street earners, hedge fund and private equity principals, and co-op owners with seven-figure compensation, a single transaction can trigger parallel federal carried-interest scrutiny and a state residency audit at the same time. Segal, Cohen & Landis has defended high-net-worth taxpayers in IRS Tax Court, offshore voluntary disclosure, and complex examination and collection matters for over 33 years, and our federal IRS practice runs nationwide from our Beverly Hills headquarters. If you have received an IRS notice, a DTF audit letter, or a residency questionnaire, the time to engage counsel is before you respond - not after.
NY
ManhattanNew York
IRS & Tax Context for Manhattan
All of New York →IRS Office for Manhattan Taxpayers
IRS New York City Office
290 Broadway, New York, NY 10007
(212) 436-1000
Federal / Tax Court
U.S. Tax Court — New York City Special Trial Session | U.S. District Court for the Southern District of New York
NY Tax Landscape
New York State taxes personal income on a graduated scale topping out at 10.9% on income over $25 million - among the highest state rates in the nation, behind only California. Manhattan residents then layer on New York City's resident income tax, which reaches 3.876%, producing a combined state-and-local marginal rate above 14.7% before a single federal dollar is counted. The New York State Department of Taxation and Finance (DTF) is wholly separate from the IRS: it runs its own audit division, its own collections arm, and its own administrative appeals process through the Division of Tax Appeals and the Tax Appeals Tribunal. A federal resolution with the IRS does not bind the DTF, and New York frequently pursues taxpayers the IRS has already closed out. DTF's signature weapon in Manhattan is the residency audit. Under the 183-day statutory residency rule and the "domicile" test, the state aggressively challenges taxpayers who claim to have moved to Florida or Connecticut while keeping a Manhattan apartment - demanding cell-phone records, EZ-Pass logs, and credit-card geolocation to prove physical presence. New York is the most litigious residency-audit state in the country, and the dollars at stake are enormous given the rates above. Manhattan's core sectors each carry distinct federal and state exposure. Financial services - hedge funds, private equity, and investment banking - face IRS Large Business and International (LB&I) scrutiny of carried interest, the Section 1061 three-year holding rule, deferred compensation under Section 409A, and RSU timing. Real estate and co-op/condo investors draw examination of Section 1031 like-kind exchanges, passive activity losses, and partnership basis. Law firms, advertising, and professional partnerships face self-employment and unincorporated business tax (UBT) issues, since NYC imposes a separate 4% UBT on partnership and freelance income that the IRS does not. The IRS office at 290 Broadway in Lower Manhattan handles examination and collection for one of the densest concentrations of high-income filers in the United States, with enforcement weighted toward unreported offshore accounts (FBAR/FATCA), crypto gains, and high-dollar collection cases. Because IRS representation is federal, Segal, Cohen & Landis serves Manhattan clients in full from our Beverly Hills base - all-remote-capable, with 33 years defending exactly this profile of high-net-worth taxpayer.
IRS Tax Services Available to Manhattan Clients
We represent clients in Manhattan and across the United States before the IRS, U.S. Tax Court, and state tax agencies. Common issues we resolve:
Why Manhattan Taxpayers Choose Segal, Cohen & Landis
Attorney-Led, Not Sales-Led
Every case is handled directly by a licensed tax attorney — never delegated to an unenrolled preparer or case manager. You get attorney judgment from day one.
33+ Years of IRS Experience
Sam Landis, Esq. has spent over three decades navigating IRS Collection, IRS Examination, and U.S. Tax Court on behalf of individuals and businesses.
National IRS Practice
We practice before the IRS in all 50 states and U.S. territories. Your physical location doesn't limit your access to experienced IRS tax counsel.
Client Reviews
Read client feedback and visit our review sources for their current ratings and review counts.
What Our Clients Say
Read client feedback on Google and Trustpilot.
“Sam resolved a six-figure IRS levy in under a week. He communicated every step clearly and got the result we needed. I can't recommend SCL highly enough.”
Michael T. · 2024
“I had an extremely complex FBAR and Form 3520 situation. Sam understood every nuance and handled the voluntary disclosure flawlessly. Genuinely the best in the field.”
Priya R. · 2024
“After receiving an IRS audit notice I was terrified. The team at SCL walked me through everything, represented me completely, and the audit closed with no changes. Worth every penny.”
David L. · 2023
Samuel Landis, Esq. · LL.M. Taxation, Boston University · 33+ years IRS controversy practice
From Our Blog
The Complete Manhattan IRS Tax Attorney Guide
In-depth overview of IRS issues, local offices, and tax landscape specific to Manhattan.
Frequently Asked Questions — Manhattan IRS Tax Help
Can a Beverly Hills tax attorney represent Manhattan clients before the IRS?
Yes. IRS practice is federal, not state-bound — an attorney admitted to practice before the IRS can represent a taxpayer anywhere in the country, including in dealings with the Manhattan office at 290 Broadway, the IRS Office of Appeals, and the U.S. Tax Court. Sam Landis holds an LL.M. in Taxation and has represented clients nationwide for over 33 years. Audits, appeals, liens, levies, installment agreements, offers in compromise, and innocent spouse claims are all handled remotely by phone, video, and secure document exchange. For purely New York State or New York City matters — such as a Department of Finance residency audit — SCL coordinates with local New York counsel while leading the federal strategy, so the two tracks stay aligned.
What tax issues are unique to Manhattan and New York City?
Manhattan's defining issue is the triple tax stack — federal, New York State (up to 10.9%), and New York City resident tax (up to 3.876%) — which pushes marginal rates toward 52% and means the IRS and NYC Department of Finance frequently audit the same return in parallel. The $10,000 SALT cap hits hardest here, where combined state, city, and property taxes routinely exceed $50,000. New York's Unincorporated Business Tax adds a layer most out-of-state advisors overlook. And Manhattan's concentration of hedge fund, private equity, and banking income makes carried interest, Section 1256, and mark-to-market elections far more common audit subjects than in almost any other U.S. city.
Does SCL handle international tax cases for New York clients?
Yes — and Manhattan generates a high volume of them. The city's large international community, including Israeli and European finance professionals, Israeli diamond merchants in the Diamond District, and Chinese real estate investors, frequently holds foreign accounts and assets that trigger FBAR (FinCEN Form 114) and FATCA (Form 8938) filing obligations. Failure to file can carry penalties of $10,000 per non-willful violation, and far more for willful conduct. SCL handles streamlined filing compliance procedures, voluntary disclosures, delinquent FBAR submissions, and penalty abatement, as well as foreign tax credit, PFIC, and controlled foreign corporation issues — all handled directly for New York clients regardless of location.
I moved from Manhattan to Florida — why is New York still auditing me, and can SCL help?
New York runs one of the most aggressive residency audit programs in the country, specifically targeting high earners who claim to have relocated to no-tax states like Florida. To shed New York residency you must overcome both the 183-day statutory residency test and the multi-factor domicile test — and auditors dig into cell phone location data, EZ-Pass records, credit card geography, club and gym memberships, where your family lives, and where your "near and dear" possessions are kept. A poorly documented move can leave you owing years of New York State and City tax plus penalties. The residency audit itself is a New York State matter, so SCL coordinates with New York counsel — but where the same income and relocation also create federal IRS exposure, SCL leads that side directly.
How quickly can you stop a wage garnishment or bank levy?
In most cases, we can issue an IRS levy release or garnishment suspension within 24–72 hours of being retained, pending IRS processing. The first step is a free consultation to assess your situation.
What is the cost of a tax attorney consultation?
We offer a free initial consultation to evaluate your situation. Fee schedules vary by case type and complexity — we are transparent about fees before any engagement.
Attorney-Led IRS Representation
Ready to Resolve Your IRS Problem in Manhattan?
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