Tax Support Resolution

Among the most frequent tax matters that clients need assistance with are:

In addition to dealing with Federal tax matters on behalf of his clients, Steven Levy is also well versed in dealing with both State and local taxing authorities on similar issues.

Case Studies


Represented a NY doctor, who while undergoing an IRS audit, was abandoned by his prior representative after the audit had already begun, leaving him open to significant civil and potentially criminal tax violations. Under severe time restraints and using the full breadth of our experience, we were able to establish that many of the “unsubstantiated expenses” which the agent initially believed to amount to more than 1 million dollars were significantly less and were not the result of any negligence by our client.

Our representation and success in this case is exemplified in our:


Represented three corporate officers of an Oil Transport company, each of whom the IRS had deemed to be “Responsible Persons” with respect to the company’s unpaid payroll taxes. Being deemed as a “Responsible Person” is a significant determination as it:

  1. Obligates that party as being one who is personally responsible for the unpaid payroll taxes, and
  2. Since payroll taxes are “trust fund taxes,” they are not eligible to be released in a personal bankruptcy and are generally not acceptable for an Offer in Compromise.

Through numerous meetings with the IRS which continued through the IRS Appeals process, we were successful in having the IRS remove the designation as “Responsible Person” for two of the company’s corporate officers. We had similar success with our representation before NYS reducing its determination that two of the corporate officers as “Responsible Persons” with respect to the company’s unpaid NYS payroll taxes to only one.

RESULT : Getting the IRS and NYS to agree that only one corporate officer should be deemed a “Responsible Person” with respect to the company’s unpaid “trust fund taxes” was not only the desired outcome from the outset of our representation; but also the best possible outcome that could be achieved in a case of this type.

Additional Case Studies in the righthand sidebar. >>>

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