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For businesses and individuals, it is never too early or too late to consult with a federal tax lawyer. We work closely with our clients and their other advisors to understand their unique circumstances and find appropriate solutions to prevent and resolve federal tax problems. Our Zaino Hall & Farrin LLC professionals use their IRS, other government, and in-house experience to provide the following:

Tax Controversy

  • Develop overall strategy for dealing with IRS Exam, Independent Office of Appeals and Chief Counsel and work closely with client to understand and document the critical facts to support legal arguments relevant to issue raised by IRS on business or individual tax audit.
  • Assist clients with challenging unwarranted tax penalties.
  • Attempt to find practical solution to resolve tax controversy at earliest possible and cost-efficient opportunity.

IRS Collections

  • Represent individuals and businesses owing income or employment (trust fund) taxes to IRS. Often our clients come to us with complicated financial affairs where they have sizable, illiquid assets but very limited cash flow.
  • Carefully understand client’s unique financial circumstances in order to make informed recommendation to clients about what resolutions alternatives (e.g., Offer in Compromise, Full or Partial Pay Installment Agreement, Currently Not Collectible status) are viable to pursue with IRS consistent with applicable federal tax law and IRS guidelines.
  • Represent client before IRS and deal directly with IRS Revenue Officer to submit comprehensive documentation to support proposal.
  • Work to prevent and reverse IRS enforcement actions such as levies and garnishments.

Tax Planning

  • Provide independent guidance to clients and their regular advisors on significant and atypical items involving tax credit, capital gains offset and other loss generating tax mitigation strategies.
  • Advise clients on various aspects of federal tax accounting, including the timing of income and expense items and impact of accounting method change procedural rules.

Employee Retention Credit (ERC)

  • Provide independent advice to clients on ERC eligibility based on statute and IRS guidance. Assist clients with enhancing documentation gathered by contingent-fee advisor, evaluating options and/or defending them on audit.
  • Assist clients with developing “reasonable cause” arguments to mitigate penalties asserted for improper ERC refund claims.
  • Advise clients on issues caused by conflicting statutes of limitations and efficacy of filing protective refund claims.

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