Tax Litigation

Tax litigation is a legal action between a taxpayer and the state or federal government. Usually, the types of issues in dispute are the omission of income or an over-reporting of deductions or credits.
Natalya’s unique skill set as a former IRS agent, her superior knowledge of tax law and procedure, plus her experience litigating all types of tax disputes in the U.S. Tax Court enables her to give you the very best representation possible. If you find yourself in a sticky tax situation, give us a call!

Liens and Levies

Our office has successfully handled numerous liens and levies. Don’t delay in calling us if you have a tax levy or tax lien. We can help by securing a temporary freeze on further collection activity, giving us sufficient time to analyze your situation and determine the best course of action.

What is a lien?

A federal tax lien is the government’s legal claim against your property when you neglect or fail to pay a tax debt. The lien protects the government’s interest in all your property, including real estate, personal property and financial assets. A federal tax lien exists after the IRS:

  • 1. Puts your balance due on the books (assesses your liability);
  • 2. Sends you a bill that explains how much you owe (Notice and Demand for Payment); and


  • 1. Neglect or refuse to fully pay the debt in time.
  • 2. The IRS files a public document, the Notice of Federal Tax Lien, to alert creditors that the government has a legal right to your property. For more information, refer to Publication 594, The IRS Collection Process (PDF).

What is a levy?

A levy is a legal seizure of your property to satisfy a tax debt. Levies are different from liens. A lien is a claim used as security for the tax debt, while a levy actually takes the property to satisfy the tax debt.

If you do not pay your taxes (or make arrangements to settle your debt), the IRS may seize and sell any type of real or personal property that you own or have an interest in. For instance,

  • 1. The IRS could seize and sell property that you hold (such as your car, boat, or house), or
  • 2. The IRS could levy property that is yours but is held by someone else (such as your wages, retirement accounts, dividends, bank accounts, licenses, rental income, accounts receivables, the cash loan value of your life insurance, or commissions).

The IRS usually levy only after these three requirements are met:

  • 1. The IRS assessed the tax and sent you a Notice and Demand for Payment;
  • 2. You neglected or refused to pay the tax; and
  • 3. The IRS sent you a Final Notice of Intent to Levy and Notice of Your Right to A Hearing (levy notice) at least 30 days before the levy.

The IRS may give you this notice in person, leave it at your home or your usual place of business, or send it to your last known address by certified or registered mail, return receipt requested.

IRS and FTB Audits

Tax audits could be very scary, cumbersome, and costly, especially, if they are not handled well from the very beginning. Hiring a tax attorney to help with an audit can benefit you in many ways. It can significantly bolster your chances of getting a fair outcome. Many people don’t realize that audits can go both ways and you may actually end up being owed money after an audit. A tax attorney can analyze your situation and find the best strategy to take in order to get the best outcome.

By allowing us to represent you, we will be able to help you in the following ways:

  • Any and all audit communications to you directly will stop. They will be directed to us, and we become the point of contact with the IRS or State tax agent assigned to your audit.
  • Proactively research any tax situations that may come up during the audit.
  • Respond to the IRS and state tax agents’ inquiries and requests for information.
  • Meet with the IRS or State agents in person, if required.
  • Negotiate and settle taxes owed if you end up owing more money during the audit and cannot pay.