News

A recent federal court decision could create significant refund opportunities for millions of taxpayers who were assessed IRS penalties and interest during the COVID-19 pandemic. While the legal issue is still being litigated, taxpayers may need to act before July 10, 2026, to preserve their right to seek a refund.

If you paid IRS penalties or interest related to late filing or late payment during the pandemic years, this development deserves your attention.

When cash flow becomes tight, some business owners delay payroll tax payments to cover payroll, rent, inventory, or other operating expenses. Unlike many business debts, however, unpaid payroll taxes often receive heightened IRS scrutiny because part of the money was withheld from employee paychecks and held in trust for the government.

As a result, payroll tax debt can lead to significant penalties, collection actions, and, in some cases, personal liability for individuals responsible for payroll tax compliance.

One of the most frustrating situations taxpayers face is making a payment to the IRS only to later receive a notice claiming the balance is still unpaid. Unfortunately, this happens more often than many people realize.

A recent federal review of IRS payment processing found that the agency still struggles to properly match certain tax payments to taxpayer accounts. When information is missing, incorrect, or incomplete, payments can end up stuck in IRS “unidentified” or “unapplied” accounts for months or longer.

For taxpayers, that can create serious problems.

In most cases, the IRS has 10 years to collect unpaid taxes. This deadline is called the Collection Statute Expiration Date, or CSED.

But the 10-year clock does not always run continuously. Certain events can pause the clock or extend the collection period, sometimes by months or even years. Because of this, calculating the true IRS collection deadline can be more complicated than many taxpayers realize.

As of late March 2026, the IRS has already received approximately 69.7 million individual tax returns. While processing this massive volume of filings, the IRS is also actively reconciling returns by matching information reported by employers and financial institutions—such as Forms W-2 and 1099—against what taxpayers report.

We are pleased to announce that two of our Attorneys were named to the 2026 Super Lawyers list, and one has been named to the 2026 Rising Stars List.  

For many taxpayers and business owners, IRS penalties can quickly turn a manageable tax issue into a significant financial burden. Whether it’s a late filing penalty or a late payment penalty, these added costs often feel disproportionate—especially when the mistake was a one-time oversight.  Now, a new proposal from the American Institute of Certified Public Accountants (AICPA) could signal meaningful change.

When people receive an IRS notice, most taxpayers don’t immediately know where to start. A quick online search often brings up dozens of advertisements from nationwide tax relief companies promising quick and guaranteed solutions, which can make it difficult to determine what type of help is actually needed. If you owe back taxes or are behind on filing returns, here are some suggestions on where to start as you discern your Tax Resolution options – tax resolution companies vs. a tax lawyer.

If you owe back taxes, delaying action can be expensive. IRS debt doesn’t stay the same.  Penalties and interest continue to accrue until the balance is resolved.

In 2025, we saved our Clients an estimated:

$672,180.46 through Audit Representation Efforts

$2,817,334.95 through Collection Statute Expiration Date (CSED) Monitoring Efforts

$795,073.64 through Penalty Abatement Efforts

$4,217,678.13 through Offer in Compromise Efforts

$8,501,924.00 in estimated 2025 Tax Savings!