We help resolve complex, high‑stakes IRS and state tax disputes

Offer in Compromise

An offer in compromise, or “OIC,” is an agreement between a taxpayer and the Internal Revenue Service allowing a taxpayer to settle their tax debt for less than the full amount owed to the IRS. OICs are a legitimate option for taxpayers who cannot pay their full tax liability, taxpayers who would face financial hardship if they were required to pay their full tax liability, or taxpayers with special circumstances which prevent them from paying.

Knudsen attorneys can assist you throughout the Offer In Compromise process. Contact Knudsen Law Firm for a free consultation to speak with us about an Offer In Compromise, the process to apply for an OIC, and how we may assist you.

Equitable Relief

Where a taxpayer does not qualify for innocent spouse relief or separation from liability relief for an item attributable to their spouse which was not reported properly on a joint return, they may request equitable relief. This type of relief may also be sought in cases where the amount of tax on a joint return is accurate but was not paid.

Knudsen attorneys can help you seek Equitable Relief. Contact Knudsen Law Firm for a free consultation to speak with us about Equitable Relief, the process to apply for Equitable Relief, and how we may assist you.

Tax of Settlements
and Judgments

Income from any source is taxable unless another section of the tax code provides an exception. One section that applies an exception to this rule is Section 104. Section 104 excepts certain types of income received through lawsuits, settlements, judgments, and awards. Despite this exception, not all types of money received from these sources qualify as excepted.

Any income received from a lawsuit, settlement, judgment, or award must be properly considered to determine the purpose for which the money was received. Depending on what the funds paid were intended to replace, tax may apply.

Knudsen attorneys can assist you with any settlement or judgment-related tax matter. Contact Knudsen Law Firm for a free consultation to speak with us about settlement and judgment tax and how we may assist you.

Internal Revenue Code Sec. 1031 Like-kind Exchanges

When a business or investment property is sold for a gain, tax on the gain must be paid at the time of sale. Section 1031 of the Internal Revenue Code provides an exception which allows a taxpayer to postpone paying tax on this type of gain if the sale proceeds are properly reinvested in similar property through a qualifying like-kind exchange.

Knudsen attorneys can help you with a Section 1031 like-kind exchange. Contact Knudsen Law Firm for a free consultation to speak with us about Section 1031 like-kind exchange and how we can help you.

Audit Defense

The Internal Revenue Service or state/local tax authority conducts tax audits. A tax “audit” is a review or examination of a taxpayer’s tax accounts and information to verify the reported information provided and the tax paid by an individual or organization is correct. A taxpayer can be randomly selected for an audit or can be asked to undergo one because issues have arisen through another taxpayer’s audit. Tax audits can be conducted in person or through the mail. Once the audit is complete, a taxpayer will receive audit findings. A taxpayer who disagrees with audit findings may be able to mediate or appeal the results of their audit.

If you are facing a federal or state audit, Knudsen attorneys can represent you. Contact Knudsen Law Firm for a free consultation to speak with us about your audit and how we may defend you.

Tax Liens

A lien is a legal claim against the property of a taxpayer who has neglected or failed to pay a tax debt. A lien secures the government’s interest but does not seize property. A lien can be filed by the Internal Revenue Service or a state or local tax authority. Once filed, a lien protects the government’s claim against a taxpayer’s property and attaches to all of the taxpayer’s financial assets, including real estate, personal property, or vehicles. A lien exists once tax liability is assessed or you receive a notice and demand for payment of tax and the period of time allowed for payment has passed. Liens apply to both individuals and businesses, and can even continue after bankruptcy.

A taxpayer facing a lien has rights and options. A taxpayer can get the IRS or a state/local tax authority to remove or “subordinate” a lien. Subordination of a lien is a process by which the IRS allows another creditor, such as a mortgage lender, to move ahead of the IRS. This can be especially beneficial to a taxpayer who is seeking to obtain a loan or mortgage.

If a lien has been filed against you, Knudsen attorneys can represent you. Contact Knudsen Law Firm for a free consultation to speak with us your tax levy and how we can help you.

State and Local Tax

In addition to federal tax, taxpayers face a variety of state and municipality taxes, laws, rules, regulations, and timeframes.  One such tax is personal income tax, which taxpayers in 43 different states must pay to the state or local municipality. A state or local tax authority may not afford a taxpayer an exception allowed by the federal government or apply it similarly.

Contact Knudsen Law Firm for a free consultation to speak with us about your international tax issue and how we can represent you.

Native American Tax

Native Americans are subject to the same income tax laws as other United States citizens unless there is an exemption explicitly created by treaty or statute. An exemption must be based on clear and unambiguous treaty or statutory language.

Although there is no general federal tax exemption for Native Americans, there are certain specific exemptions and other tax provisions which do apply to Native Americans. There are numerous valid treaties between specific federally-recognized tribal governments and the U.S. government, which apply specific narrowly-defined tax exemptions or exemptions to specific tribes and their members.

Contact Knudsen Law Firm for a free consultation to speak with us about your Native American tax issue and how we can help you.

Currently not Collectable

In many cases, a taxpayer may owe the Internal Revenue Service but be unable to pay their tax debt because their current financial situation does not allow them to pay both basic living expenses and their tax liability. In such cases, a taxpayer who has no outstanding tax returns may ask the IRS to review their financial circumstances. If upon review, the IRS agrees, it may place your account into Currently Not Collectible, or “CNC,” status.

While your account is in CNC status, the IRS will typically refrain from attempting to collect from you. Your tax debt will remain, and interest and penalties will still continue to accrue. The IRS may keep any tax refunds due to you and apply them to your tax debt. You will still be required to file tax returns and make estimated tax payments or deposits while your account is in CNC status.

Knudsen attorneys can represent you in the Currently Not Collectible process. Contact Knudsen Law Firm for a free consultation to speak with us about Currently Not Collectible, the process to apply for CNC, and how we may assist you.

Estate Tax

The estate tax is a tax on a person’s right to transfer property when they die. To calculate estate tax, a fair market value of property and certain interests, such as cash, securities, real estate, insurance, trusts, annuities, business interests, and other assets, is determined. This sum represents the “gross estate.”

A series of deductions and reductions are applied to the gross estate to determine the “taxable estate.” Once a taxable estate is determined, the value of any gifts made after 1977 is added to the figure, and tax is computed. The resulting tax is then reduced by any unified credit.

An estate reports tax on an estate tax return. Most individuals have simple estates which do not require the filing of an estate tax return. Estates with more considerable assets and those of individuals with prior taxable gifts are required to file an estate tax return. Certain spousal elections must also be made on estate tax returns.

Knudsen attorneys can represent you in any Estate Tax matter. Contact Knudsen Law Firm for a free consultation to speak with us about Estate Tax and how we may assist you.

Business Tax

Nearly every business is required to file an annual tax return. The type of form used to report income depends on how a business is established. Tax must be paid as income is earned or received.

Employees typically have tax withheld from their pay. If tax is not paid through withholding, estimated taxes may have to be paid at required times or when an individual return is filed.

In addition to income taxes, there are other types of taxes that businesses and their owners and operators may encounter, including self-employment tax, employment tax, excise tax, and others.

Knudsen attorneys can assist you with any business tax matter. Contact Knudsen Law Firm for a free consultation to speak with us about business tax and how we may assist you.

Internal Revenue Code
Sec. 1033 Election

When property is sold for fair market value in an amount in excess of the property’s “adjusted basis,” or adjusted ownership cost, gain occurs. This type of gain from the sale or other disposition of property must be realized and tax must be paid at the time of sale.

Section 1033 provides an exception to this requirement for gain from property that is involuntarily or voluntarily partially or completely destroyed, stolen, seized, requisitioned, or condemned. A taxpayer must make an election to utilize this exception and replace the property with similar or related property in a specified period.

If you own property that has faced, or will face, destruction, theft, seizure, requisition, or condemnation, Knudsen attorneys can assist you with a Section 1033 like kind exchange. Contact Knudsen Law Firm for a free consultation to speak with us about your situation and how may assist you.

Payroll and
Employment Taxes

There are multiple different types of federal, state, and local taxes which apply to employees, employers, and self-employed taxpayers. Examples include social security and Medicare taxes, Federal Unemployment Tax (FUTA), and self-employment tax. Employers must properly withhold, deposit and report employment taxes. Businesses and individuals who violate employment tax laws may be subject to significant penalties, interest, and liens. Civil and criminal sanctions and even jail sentences can apply.

If you have a payroll or employment tax issue, Knudsen attorneys can help you. Contact Knudsen Law Firm for a free consultation to speak with us about payroll and employment taxes and how we may assist you.

Wage Garnishment or
Wage Execution

A “wage garnishment” or “wage execution” is a “levy,” or seizure of part of a taxpayer’s wages by the Internal Revenue Service or a state/local tax authority to pay the tax debt of a taxpayer who has not otherwise paid or made arrangements to pay.

Typically, the IRS will take all of the taxpayer’s wages above and beyond an amount based on the standard deduction plus an amount determined by the number of dependents a taxpayer has in the year the wage garnishment begins. The IRS may take any income above and beyond this calculated amount, including amounts for bonus income. The IRS will notify a taxpayer’s employer and garnish wages directly from the employer. The IRS will continue to garnish a taxpayer’s wages until the tax debt, including penalties and interest, is satisfied, a hardship is proven, the taxpayer enters into a collection agreement, or the period of time in which the tax debt must be collected has passed. A taxpayer with outstanding tax returns will be required to file all required returns before a levy will be removed.

If you have had your wages garnished, Knudsen attorneys can assist you. Contact Knudsen Law Firm for a free consultation to speak with us about your wage garnishment and how we can help you.

Virtual Currency and
Cryptocurrency tax

Virtual currency transactions are taxable just like transactions on other property. Virtual currency, which is a digital unit of value that may be exchanged, includes cryptocurrency, which is a type of virtual currency that uses cryptography to authenticate and protect digitally-recorded transactions. Taxpayers who engage in any virtual currency transaction may be required to report virtual currency transactions on their tax returns. “Convertible” virtual currency, which is a virtual currency that has an equivalent value to real currency, such as Bitcoin, is another common type of virtual currency.

Investment in, the sale of any virtual currency, or the use of virtual currency to pay for goods and services can result in tax liability.

If you are facing a virtual currency-related tax issue, Knudsen attorneys can help you. Contact Knudsen Law Firm for a free virtual currency tax consultation and to see how we may represent you.

Non-Profit or Exempt
Organization Tax

The term “non-profit” is well-known. It refers to a tax-exempt organization or association. The United States tax code contains laws that allow for dozens of different types of exempt organizations. There are five types of exempt organizations. The first is charitable organizations, which are organized and operated exclusively for religious, charitable, scientific, public safety testing, educational, or other specified purposes which meet the tax-exemption requirements outlined in Section 501(c)(3) of the code. Section 501(c)(3) also authorizes a second type: churches and religious organizations. Private foundations, which typically have a single primary source of funding and primarily make grants to other charities and individuals but do not directly operate charitable programs themselves, are the third type. Another section of the code establishes a fourth type of tax-exempt organization, specifically political organizations. The final type of tax-exempt organization is other organizations that qualify tax exemption under a section of the tax code other than Section 501(c)(3), including social welfare organizations, civic leagues, labor organizations, and business leagues.

Contact Knudsen Law Firm for a free consultation to speak with us about an aspect of your non-profit or exempt organization tax matter and how we can assist you.