We advise individuals, families and business owners on planning that keeps tax consequences in view before a decision is made, and we represent clients when a taxing authority pushes back.
When an attorney represents you in a tax dispute, your communications with counsel are generally protected by the attorney-client privilege. The privilege has limits. It generally does not cover information used to prepare a tax return.
Property & local tax
Assessment appeals, personal property tax and sales-and-use tax.
IRS collection defense
Audits and appeals, levies and liens, installment agreements, offers in compromise, innocent-spouse relief and more.
Planning
Entity structuring and transaction planning, with the tax consequences considered up front.
Property & local tax
- Property Tax & Local Tax Services
- Property Tax Assessment Appeal
- Personal Property Tax Services
- Sales & Use Tax Services
IRS tax collection defense
Additional tax services
- U.S. Tax Court petitions and litigation
- Washington Department of Revenue audits and Board of Tax Appeals appeals
- Washington capital gains tax
- Estate, gift and trust tax returns (Forms 706, 709, 1041)
Frequently asked questions
Why hire an attorney instead of a CPA or enrolled agent for an IRS problem?
CPAs and enrolled agents can represent you before the IRS, and for many matters that is enough. An attorney makes sense when the case may go to court, when there is any risk of a fraud referral, or when you want your communications protected by the attorney-client privilege. Edward J. Barton is an attorney and a CPA, and he is admitted to practice before the United States Tax Court.
The IRS levied my bank account. What now?
Your bank must hold the funds for 21 days after it receives the levy before sending them to the IRS. Call us right away. That window is the best time to get a levy released.
How long does the IRS have to collect?
Generally 10 years from the date the tax is assessed (IRC 6502). An offer in compromise, bankruptcy and some other requests pause the clock. If you never filed a return, the clock hasn't started.
Will I go to jail for not filing?
Prosecution is rare and requires willful conduct. Willful failure to file is a misdemeanor (IRC 7203). Tax evasion and filing a false return are felonies. Getting back into compliance before the IRS contacts you puts you in the strongest position.