Straight answers about IRS collection, your options, and what representation actually does.
Getting Started
Tax resolution is the process of resolving an outstanding tax liability through the programs the IRS makes available — payment arrangements, penalty relief, hardship status, and in qualifying cases a formal compromise. An attorney reviews your complete tax and financial position, identifies which options you actually qualify for under current law, and deals with the IRS on your behalf. Most clients never speak with the IRS directly once representation is in place.
Tim will ask what notices you have received and when, roughly what is owed, and whether collection has started. From that he can usually tell you what you are facing and what the realistic options are. If the matter does not warrant attorney representation, he will say so. The call is confidential and protected by attorney–client privilege.
It depends on the number of years or quarters involved, whether enforcement has begun, and the complexity of the resolution. Tim gives a straight assessment of scope and fee on the first call rather than a quote from a script. We focus on matters over $10,000.
No. Most matters are handled by phone, email, and secure document exchange. Our office is in Atlanta and we are glad to meet in person, but it is rarely necessary.
IRS Collection
Ignoring notices is among the costliest mistakes a taxpayer can make. IRS collection follows a defined escalation, and each unanswered notice moves you further along it. Once a Final Notice of Intent to Levy is issued, you generally have 30 days to respond before the IRS can levy wages, bank accounts, and other assets without further warning. Many IRS deadlines cannot be reopened once missed.
It is possible but uncommon, and seizure of a primary residence requires court approval. Far more common are wage garnishments, bank levies, and federal tax lien filings. A lien is not a seizure — it is a public claim against your property that surfaces in credit reviews and can block a sale or refinance.
The IRS generally has ten years from the date of assessment to collect, known as the collection statute expiration date. Certain events pause that clock, including bankruptcy, pending offers, and installment agreement requests, so the actual date is often later than a simple ten-year count suggests. We calculate it from your account transcripts rather than estimating.
Yes, and the sooner the better. Levy releases are available in defined circumstances, and most enforcement notices carry appeal rights that expire on a fixed deadline. Acting quickly preserves options that disappear with time.
Your Options
In qualifying cases, yes. The Offer in Compromise program allows eligible taxpayers to resolve a liability for less than the full amount, based on income, allowable expenses, asset equity, and future earning capacity. Qualification is strict and most applicants do not meet it. Any firm guaranteeing acceptance is misleading you — nobody can guarantee what the IRS will approve. What we offer is an honest assessment of whether you qualify and real representation if you do.
Currently Not Collectible status may apply where paying would leave you unable to meet basic living expenses. It pauses active collection, though penalties and interest continue and the IRS reviews the status periodically. It is a legitimate outcome, not a failure.
Sometimes. Relief is available for reasonable cause, and first-time abatement applies where your prior compliance history qualifies. Penalties can make up a substantial share of a balance, so it is worth examining properly rather than assuming.
For a small balance with no enforcement, sometimes yes. The calculation changes once a Revenue Officer is assigned, a levy has issued, a deadline is running, or the amount is large enough that a mistake is expensive. Anything you say to the IRS becomes part of the record.
Business and Payroll Tax
Very. Employment tax is the IRS's highest collection priority, because the withheld portion was taken from employees and held in trust. Those cases escalate faster, draw Revenue Officer assignment sooner, and carry a feature no income tax balance has: the trust fund portion can be assessed against you personally under IRC § 6672.
For the trust fund portion, yes. Limited liability protects owners from ordinary business debts. It does not protect against a Trust Fund Recovery Penalty assessment, because that assessment is against the individual, not the company. It survives dissolving the business and is generally not dischargeable in bankruptcy.
Potentially. The IRS applies a functional test — check-signing authority and control over which creditors got paid can be enough without any ownership stake. Non-owners in this position often need representation separate from the company's, because the interests may not align.
Working With Us
Yes. Communications with an attorney for the purpose of legal advice are protected by attorney–client privilege. That protection does not extend to a CPA, a payroll provider, or a tax resolution company, and those parties can be summonsed.
Practice before the IRS is federal, so we represent clients on federal tax matters nationwide. For Georgia clients we also handle Georgia Department of Revenue matters, which frequently run alongside a federal case.
With Tim. You work directly with him from the first call to the day the case closes — not a paralegal, not a rotating case manager.
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An active levy or lien means the IRS is already collecting. Every day without legal representation costs you money. Call Tim Wooten now — he personally handles every case.
Acting before the IRS escalates gives you the most choices — and the best outcomes. Tim Wooten will personally review your situation and tell you exactly what can be done.
Many of our clients come to us after another firm or CPA was unable to resolve their case. Attorney representation — with full litigation capability — changes the dynamic with the IRS. Let's review what happened and what options remain.
Case Review Complete
Our firm focuses on cases over $10,000.
For balances under $10,000, full attorney representation may cost more than it saves. The IRS Taxpayer Advocate Service may be able to help at no cost: 1-877-777-4778. If your balance grows or the IRS escalates, we are here.