Segal, Cohen & Landis, P.C.
Get Back Into Compliance — We Handle Years of Unfiled Returns
IRS tax attorneys — Beverly Hills, CA. National representation.
Failing to file federal tax returns is a serious problem that only gets worse with time. Unfiled returns expose you to the IRS's Substitute for Return (SFR) process — where the IRS files returns on your behalf using only the income information it has (W-2s, 1099s) and none of your deductions, exemptions, or credits. SFR assessments routinely result in tax liabilities many times higher than what you would have owed if you had filed correctly. Beyond inflated liabilities, unfiled returns can trigger criminal referrals for willful failure to file — a felony. At Segal, Cohen & Landis, we help clients with multiple years of unfiled returns get back into compliance, minimize the resulting liability, and resolve any collection issues with the IRS.
How We Help
Our Approach to Unfiled Tax Returns Attorney
Delinquent Return Preparation
We gather historical income records (IRS transcripts, 1099s, W-2s, bank records), prepare accurate amended or original returns for all unfiled years, and file them in a way that minimizes liability and presents your situation favorably.
SFR Mitigation
If the IRS has already filed SFRs for years you haven't filed, we prepare and file original returns to replace the SFRs. Original returns filed after SFRs can dramatically reduce the assessed balance by capturing deductions and credits the IRS missed.
Voluntary Disclosure and Criminal Risk Management
For taxpayers who have failed to file for many years or who have unreported income, we assess criminal risk and, when appropriate, design a voluntary disclosure approach that minimizes exposure and restores compliance.
Post-Filing Resolution
Filing the returns is step one. Step two is resolving the resulting liability — whether through installment agreements, OIC, penalty abatement, or CNC status. We manage the entire process end-to-end.
How It Works
The Resolution Process
IRS Transcript Pull
We pull all available IRS transcripts to identify which years have not been filed, whether SFRs exist, and what income information the IRS already has.
Income Reconstruction
We gather records from all available sources and reconstruct income for each unfiled year, ensuring all legitimate deductions are captured.
Return Preparation and Filing
We prepare and file all delinquent returns, replacing any existing SFRs and ensuring the most accurate and favorable filing position for each year.
Balance Resolution
We negotiate resolution of any resulting liabilities — installment agreements, OIC, penalty abatement — as part of the same engagement.
Ready to Resolve Your Tax Problem?
Our attorneys have helped thousands of clients resolve IRS matters. Your consultation is free and confidential.
Common Questions
Frequently Asked Questions
How many years of unfiled returns do I need to file?+
The IRS requires at least 6 years of back returns to be considered in full compliance (the current year plus the 5 prior years). In some cases, we advise filing more. We evaluate each situation individually.
What happens if I don't file?+
The IRS may file SFRs on your behalf — always without your deductions. They can also assess substantial civil penalties and refer your case for criminal prosecution if the failure to file appears willful.
Can I get penalized even if I'm due a refund?+
If you're owed a refund, there is no penalty for late filing — but the IRS has a 3-year window to claim your refund after the due date. After 3 years, refund rights are forfeited. If you're overdue, don't wait.
What is the criminal exposure for unfiled returns?+
Willful failure to file is a federal misdemeanor (26 U.S.C. §7203) with up to 1 year imprisonment per year. Willful tax evasion is a felony. Most cases involving unfiled returns that come to us are handled civilly — but criminal risk depends on the circumstances, which we evaluate immediately.
Further reading
Beverly Hills · Los Angeles · National
Segal, Cohen & Landis, P.C.
9100 Wilshire Boulevard, 601 East Tower, Beverly Hills, CA 90212
Free Confidential Consultation