Both the state and federal governments rely on tax revenue to pay for its various services. However, the laws governing how taxes are filed and reported are complicated, and can often change based on new legislation. Because of this, it is not unusual for a taxpayer to make a mistake. Many of these mistakes can be fixed by speaking with a Rockville tax law firm, but in some rare situations, the Internal Revenue Service (IRS) or the Comptroller of Maryland might get involved.

A Rockville tax attorney could help individuals or businesses settle a tax controversy by either filing returns or paying the tax as required. Our tax law firm could also provide you with guidance on how to effectively challenge a tax assessment that may have been made in error.

Resolving Tax Controversies for Offshore Financial Accounts

One of the primary areas that Pontius Tax Law works in is tax controversies involving offshore financial accounts. Taxpayers who make income overseas or hold it in foreign financial accounts must still report it to the IRS and pay the relevant tax, under U.S. law. If they do not report it or pay the tax, they are at risk of civil penalties, with any willful actions potentially leading to criminal exposure. If a taxpayer finds themselves in one of these sensitive “eggshell” situations, a skilled tax controversy lawyer in Rockville could analyze their situation and determine how they can safely disclose their unreported income. This includes filings that fall under FBAR and FATCA reporting rules.

Investigations and Appeals

The IRS and State Comptroller have the power to investigate any taxpayer to enforce compliance with the law. While most tax controversies only pose the risk of civil penalties, there remains the possibility of a criminal investigation if the taxpayer took willful actions to not file or pay their taxes. The escalation into a criminal matter is possible during an investigation for tax fraud. To reduce the odds of this, it is best to retain legal counsel the moment that a taxpayer is notified that an agency is investigating; or, if possible, before an agency is even aware that some tax returns were never filed.

The Taxpayer Bill of Rights § 5 states that all taxpayers have the right to appeal an IRS decision. Maryland law allows for similar rights to appeal. A Rockville tax lawyer could help someone file an appeal to challenge the findings of an audit if they believe that an assessment was made in error. This filing must be done carefully and accurately, which is why it is important to do so with the aid of a tax law firm. Any individual can also challenge the assessment of a tax in Maryland Tax Court on their own but should consider legal counsel if the amount at issue is more than $50,000.

Other Tax-Related Events That an Attorney Could Assist With

The tax system is complicated and there are more situations beyond offshore disclosures or tax fraud that might require careful action. A Rockville tax attorney could work with an individual or a business to address a controversy in any of the following ways:

  • Penalty Abatement: While working to address another sensitive tax situation, if an attorney finds that an IRS penalty was assessed in error, they could help demonstrate that the penalty and its resulting interest should be abated.
  • Liens and Levies: The IRS has the power to impose liens on one’s property as a signal to creditors that a debt has yet to be paid, or they can acquire a property through a tax levy unless a debt is fulfilled. A lawyer can work with a taxpayer to determine the best method to release a levy or discharge a lien in a way that makes the most financial sense.
  • Trust Fund Recovery Penalty: A legal professional could assist a business that the IRS determined has failed to remit their trust funds taxes, or who requires an alternative means of fulfilling their obligations.
  • IRS Collections: If a tax bill is owed, a lawyer could identify and request permission to set up an installment agreement or an Offer in Compromise to ease the burden of having to pay.
  • State Tax Issues: In addition to the IRS, Pontius Tax Law can assist a taxpayer in any dispute they have with the State of Maryland, including questions about residency.

Contact a Rockville Tax Lawyer Today to Learn More

Taxpayers with significant financial assets and multiple reporting obligations must take care to remain compliant with the IRS. But despite someone’s best efforts and intentions, tax controversies can still arise. These can include audits that require additional payments or inquiries regarding the source of income.

No matter your exact needs, a Rockville tax attorney could provide invaluable assistance and work with you to come up with comprehensive solutions to your current problem. Call our tax law firm to discuss your situation.

Attorney John Pontius

Pontius Tax Law, PLLC is a tax law firm that strives to resolve sensitive tax problems through trust, dedication and value. The law firm was founded by John Pontius with offices in Washington, DC,  Rockville, MD, Bethesda, MD, Fairfax, VA, and Alexandria, VA. Mr. Pontius represents individual and business clients with sensitive and serious tax matters before the Internal Revenue Service and state taxing authorities. His client base is local, national, and international.

Over the course of his career, Mr. Pontius has represented businesses and individuals with complex tax issues in the following areas: FBAR examinations, offshore and domestic disclosures, FATCA, FIRPTA, tax planning, unfiled tax returns, release of tax liens and levies, trust fund recovery penalty, IRS and state audit examinations, as well as appeals, penalty abatement, U.S. Tax Court litigation, along with defense of tax fraud and evasion. If you require assistance from a tax lawyer, contact Mr. Pontius to discuss your situation.

Client Reviews
John helped us with a DC tax audit and succeeded in getting us a "no change" final decision. The issues were related to two flow-through entities and the use of carry-forward operating losses -- something that the DC auditors struggled to understand and with which they did not have any...
Paul A
Mr. Pontius is extremely professional and was able to take care of my tax returns which includes international bank accounts quickly and at a very reasonable price. Would definitely recommend.
I received a fee this past November from the IRS for over $800 because of an error I made on my 2016 taxes. I called my cousin, John Pontius, and he immediately knew what steps needed to be taken. Thanks to him, the fee was cleared. A 10 minute conversation...
As an American citizen living in the Middle East my local banker informed me that I needed to file FBARs and report my worldwide income to the IRS. Through the recommendation of another attorney at an international law firm, I was introduced to John Pontius. Mr. Pontius efficiently and effectively...
Kareem S
John handled a difficult IRS lien for my client. He was excellent in getting the lien released so we could close on the property. I would highly recommend John .
Bobbie M
We were seeking tax advice with managing two properties, LLC, as well as some future financial planning. John responded to my call in a timely manner and was happy to answer our questions while referring us to specialists who can manage our accounts on a more regular basis.
Janelle M
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