Alvin Brown and Associates is a tax law firm representing taxpayers throughout the U.S. and abroad before the IRS. IRS representation is the specialty of our tax law firm. Our representation includes civil and criminal examinations, collection issues, tax settlements, tax liens, tax abatements, advisory opinions and similar matters involving representation and interaction with the Internal Revenue Service.
We are "advocates" in our representation of taxpayers before the IRS. In that advocacy we use legal memoranda, as needed, to support our advocacy based on the Internal Revenue Code, tax regulations, IRS administrative manuals, published IRS positions, the tax legislative history to support our oral advocacy. It is very important to support a taxpayer position for the administrative record given the review of tax matters by managers, reviewers, other management, and the IRS Office of Appeals. Some tax issues depend on State law, and we research and use State law as needed. We use a have a daily tax service for new case law and current legislative changes as they occur. Our specialized IRS tax practice is comprehensive.
We also give advice and assist accountants, CPA, enrolled agents and other attorneys who do not have our technical expertise and insight into IRS practices, procedures. We respect the law that Congress writes and one of our primary goals to make sure that the IRS makes its determinations with "integrity" and "fairness." Unfortunately, the IRS is not always fair in the exercise of its discretion, its determinations on factual issues and its application of the tax law. For that reason we extend ourselves in our representations to be equally aggressive if necessary.
It is very difficult to help any taxpayer unless they are in compliance in filing their tax returns. W-2 employees must file all tax returns annually, and Form 1099 employees must file quarterly self-employment tax returns. All tax returns are an affidavit signed under penalties of perjury. Therefore, it is critical that tax returns be prepared in good faith and at the highest level of accuracy.
We will assist taxpayers who have not filed tax returns with tax return preparation. Tax returns that are not filed put taxpayers at an enormous disadvantage because:
If information is incomplete tax returns should nevertheless be filed with full disclosure on any information that is incomplete or undocumented as long as the filing is not frivolous. We assist taxpayers who have incomplete data, lost records, or other filing problems. It is imperative that tax returns be filed timely notwithstanding current filing issues. All unfilled tax returns must be filed. The IRS will not accept an Offer in Compromise to reduce a tax debt unless all tax returns are filed. An Installment Agreement is available for those who may not qualify for an Offer in Compromise.
Tax returns may be filed even if the IRS filed a tax return under its authority to prepare tax returns for those who have not filed tax returns. We assist with amended tax returns and challenges to a tax liability that may be challenged, including the trust fund recovery penalty.