Atlanta IRS Negotiation Lawyer

Wiggam Law represents Atlanta individuals and businesses in IRS collection negotiations, including installment agreements, offers in compromise, penalty abatement, Currently Not Collectible status, and Collection Due Process hearings. 

Our tax law practice is exclusive, and our team includes former IRS Revenue Officers whose experience inside the agency informs the strategies we build for clients on the outside.

Every IRS notice arrives with a bigger number than the one before. The balance on the CP14 becomes the balance on the CP503, then the CP504, then the LT11 Notice of Intent to Levy.

Failure-to-pay penalties are added each month under IRC § 6651(a)(2). Interest accrues daily at the federal short-term rate plus 3% under IRC § 6621. By the time the taxpayer decides to do something about it, the balance is thousands of dollars higher than the amount shown on the first bill. 

The Atlanta IRS negotiation attorney engaged before the LT11 window closes is the one who can freeze the growth and begin bringing the number down. 

Negotiation happens outside that automated framework, through the specific procedural mechanisms the Internal Revenue Code authorizes: installment agreements under IRC § 6159, offers in compromise under IRC § 7122, currently-not-collectible status, penalty abatement under the First Time Abate program and reasonable cause standards, and Collection Due Process hearings under IRC §§ 6320 and 6330. 

Each mechanism has its own eligibility rules, financial disclosure requirements, and procedural deadlines. Getting the right mechanism in front of the IRS at the right time is the work.

Our attorneys hold advanced tax credentials, including LLMs in Taxation. We handle Georgia Department of Revenue collections in parallel with federal matters. 

From installment agreements and offers in compromise to Collection Due Process hearings and levy release, we build a resolution strategy that aligns with the client's financial reality and the IRS's procedural rules. 

Call (404) 609-1300 in Atlanta to discuss the balance in front of you.

Why Clients Choose Wiggam Law in Atlanta for IRS Negotiation Cases

The IRS collection function is a procedural machine. Negotiating with it requires knowing where the machine's decision points sit and how each one shifts the case posture.

Tax Law Exclusively

Every attorney at our firm works on tax matters. IRS collection negotiation is a core practice area, not an adjacent service we occasionally touch.

Former IRS Revenue Officer Experience

Members of our team worked on collecting money from inside the agency. We know how a Revenue Officer builds a case file, how the Collection Financial Standards are actually applied in the analysis, and where the discretionary points in the process are that a taxpayer without representation typically misses.

Advanced Tax Credentials

Our attorneys hold LLMs in Taxation and have significant experience in dealing with the IRS and state taxing agencies. Collection cases that escalate to litigation are handled by counsel already admitted to the relevant forum.

Full Resolution Toolkit Under One Practice Group

Installment agreements, offers in compromise, currently-not-collectible status, penalty abatement, Collection Due Process hearings, and lien and levy work all fall within our federal tax controversy practice, with each case worked by a team of attorneys, enrolled agents, and paralegals as cases move between mechanisms.

Federal and Georgia State Coordination

IRS negotiations frequently run in parallel with Georgia Department of Revenue collection actions. We handle both fronts in a single coordinated strategy.

Strategic, Not Sympathetic

The IRS does not reduce a taxpayer's balance based on how difficult the situation is. We build the financial case and legal framework that produces an actual resolution.

Challenges Taxpayers Face in IRS Negotiations and How We Respond

IRS collection negotiations are full of decision points that either open up resolution options or close them. Recognizing the pressure points early is part of the defense.

• Automated collection escalates without human review: The IRS's Automated Collection System (ACS) escalates cases based on age and balance, with levies and wage garnishments issuing automatically once thresholds are crossed. We move the case out of the automated track and into representation before enforcement triggers.
• Revenue Officer assignment changes the calculus: Cases assigned to a Revenue Officer are handled by a human collection agent who can be negotiated with directly, but who also has broader enforcement authority than ACS. We handle Revenue Officer cases through direct communication under Form 2848 Power of Attorney.
• Collection Financial Standards are both non-negotiable and flexible: The IRS applies national and local standards for housing, transportation, food, and other expenses. Knowing where the standards can be exceeded (medical expenses, court-ordered obligations, certain business expenses) and where they cannot is the difference between a workable resolution and a proposed monthly payment you cannot make.
• Financial disclosure drives outcomes: OIC applications, IA requests, and CNC petitions all turn on financial disclosure on Form 433-A, 433-F, or 433-B. Errors and omissions produce delays and denials. We build the disclosure with the specific resolution mechanism in view from the first draft.
• Filing compliance is a threshold requirement: The IRS will not negotiate any resolution with a taxpayer who has unfiled returns. We handle the compliance work first when catch-up filings are needed.
• The Collection Statute Expiration Date drives strategy: The IRS has 10 years from assessment to collect under IRC § 6502, subject to specific tolling events. Where the CSED is close, the calculus on OIC versus partial payment installment agreement versus CNC status shifts substantially.
• Deadlines run on notices most taxpayers overlook: the 30-day Collection Due Process window on a Letter 3172 lien notice or an LT11 levy notice, the 30-day period to appeal an OIC decision, and the 21-day bank levy release window all run on the IRS's calendar, not the taxpayer's.

Who We Represent in Atlanta IRS Negotiation Cases

Our clients fall into three broad categories, though the specific procedural posture drives the strategy in every case.

1. Individuals with unpaid federal tax debt. W-2 employees, self-employed individuals, and retirees with assessed federal tax liabilities that have moved from the ACS notice sequence into active collection. Many arrive with substitute-for-return assessments under IRC § 6020(b), in which the IRS filed a return on the taxpayer's behalf, resulting in an inflated balance that requires a compliance filing before negotiation can begin. Others arrive after a completed audit, with the assessed adjustment now sitting in collections.
   
2. Business owners and executives. Owners with 941 or 940 collections often face Trust Fund Recovery Penalty assessments under IRC § 6672, and we coordinate the business and personal tracks so neither is undermined by the other. High-income filers with six- and seven-figure liabilities from complex returns, K-1 items, or resolved Wealth Squad audits also fall in this category, along with business owners facing simultaneous IRS and Georgia Department of Revenue collection actions.
   
3. Special-circumstance filers. Taxpayers facing passport revocation under IRC § 7345 whose passports have been denied, revoked, or are at risk. Filers seeking innocent spouse relief under IRC § 6015 on joint returns where the tax liability is attributable to the other spouse. Personal representatives resolving decedent tax debts for estates. Each of these carries its own procedural rules and its own defense strategy.
   

Types of IRS Negotiation Cases We Handle

We represent Atlanta clients across the full range of IRS collection resolution mechanisms.

Case Type	Authority	What It Involves
Guaranteed Installment Agreements	IRC § 6159	Balances under $10,000 with mandatory acceptance and no financial disclosure
Streamlined Installment Agreements	IRC § 6159; IRM 5.14	Balances up to $50,000 with limited disclosure and terms up to 72 months
Standard Installment Agreements	IRC § 6159; IRM 5.14	Larger balances requiring Form 433 disclosure and Collection Financial Standards analysis
Partial Payment Installment Agreements	IRC § 6159(a)	Reduced payments where the CSED will expire before full retirement of the liability
Offers in Compromise	IRC § 7122	Settlement of tax debt based on Reasonable Collection Potential
Currently Not Collectible Status	IRM 5.16.1.1	Suspension of active collection where economic hardship exists
First Time Penalty Abatement	IRM 20.1.1.3.6	Removal of failure-to-file, failure-to-pay, and failure-to-deposit penalties for compliant taxpayers
Reasonable Cause Penalty Relief	IRC § 6651(a)	Fact-based penalty relief where reasonable cause exists
Lien Withdrawal, Subordination, and Discharge	IRC §§ 6323(j), 6325	Reversal or repositioning of federal tax liens
Levy Release	IRC § 6343	Release of active bank levies, wage garnishments, and accounts receivable levies
Collection Due Process Hearings	IRC §§ 6320, 6330	Independent Appeals review of proposed collection actions
Passport Revocation Reversal	IRC § 7345	Removal of seriously delinquent tax debt certification
Innocent Spouse Relief	IRC § 6015	Relief from joint liability under subsections (b), (c), or (f)

The IRS Resolution Toolkit

Successful negotiation with the IRS happens through specific procedural mechanisms the Internal Revenue Code authorizes. Each has its own eligibility framework and financial disclosure requirements. Matching a client to the right mechanism is the core of the work.

Installment Agreements

An installment agreement (IA) is the most common resolution path for taxpayers who can pay the liability over time. The IRS offers several variants, each with different eligibility criteria and disclosure requirements.

• Guaranteed Installment Agreement: For balances under $10,000 with a five-year filing compliance history, the IRS is statutorily required to accept the agreement. No financial disclosure is required.
• Streamlined Installment Agreement: For balances up to $50,000, the IRS accepts installment terms of up to 72 months with minimal financial disclosure. This is the workhorse resolution for most individual taxpayers.
• Standard Installment Agreement: For balances over $50,000, the IRS requires Form 433-A or 433-F financial disclosure and applies Collection Financial Standards to determine acceptable monthly payments.
• Partial Payment Installment Agreement: Under IRC § 6159(a), where the taxpayer's monthly payment capacity will not retire the liability before the CSED, the IRS accepts a partial-payment arrangement and allows the balance to expire uncollected at CSED.

Installment agreement negotiation is not a form-filling exercise. The critical work happens in the Collection Financial Standards analysis, where the difference between what the IRS treats as a "necessary" expense versus a "conditional" expense determines the monthly payment a client can actually afford. Where the standards are applied mechanically, the resulting payment is often higher than the client's actual disposable income supports.

Offers in Compromise

An offer in compromise (OIC) under IRC § 7122 is a settlement of federal tax debt for less than the full amount owed. It is the most talked-about IRS resolution mechanism and the most misunderstood. 

Three statutory bases are available: doubt as to collectibility, where the taxpayer's Reasonable Collection Potential is less than the assessed liability; effective tax administration, where collection in full would be inequitable despite theoretical ability to pay; and doubt as to liability, where the taxpayer disputes that the tax is actually owed. Doubt as to collectibility drives the majority of accepted offers.

The application requires Form 656 (the offer itself), Form 433-A(OIC) or 433-B(OIC) financial disclosure, an application fee, and either a 20% lump-sum initial payment or the first monthly payment on a periodic-payment offer. Accepted offers require five years of subsequent tax compliance. Any default within the five-year window reinstates the original liability plus accrued penalties and interest.

The OIC is not a "pennies on the dollar" program in the way that late-night television ads suggest. The IRS accepts OICs that equal the taxpayer's Reasonable Collection Potential (RCP), calculated from asset equity plus a multiple of monthly disposable income based on the payment structure of the offer. 

The work of an OIC involves building the RCP calculation and the accompanying financial disclosure to produce a viable offer and structuring the payment terms to fit the client's cash flow.

Currently Not Collectible Status

For taxpayers whose financial position does not support any payment, the IRS will suspend active collection under Currently Not Collectible (CNC) status, referred to internally as "Status 53". CNC is granted where collection would cause economic hardship under IRC § 6343(a)(1)(D), defined as the inability to meet reasonable basic living expenses under Collection Financial Standards. The status requires Form 433-A or 433-F disclosure with supporting documentation.

CNC is not a resolution in the same sense as an IA or OIC. It is a suspension. Interest and any statutory penalties continue to compound on the assessed amount, and the status is reviewed periodically; improved financial circumstances can lift the status and reactivate collection. What CNC does provide is time. 

The 10-year Collection Statute Expiration Date under IRC § 6502 continues to run during CNC status, and for taxpayers close to the CSED, that suspension can be the effective resolution if collection stops long enough for the statute to expire.

Penalty Abatement

Federal tax penalties can be abated through several distinct procedural pathways, each with its own eligibility standard.

• First Time Abate (FTA): An administrative program under IRM 20.1.1.3.6 that removes failure-to-file, failure-to-pay, and failure-to-deposit penalties for taxpayers with a clean three-year compliance history. FTA is granted on request without a factual reasonable-cause showing, once per taxpayer per tax type per compliance window.
• Reasonable Cause: Under IRC § 6664(c) and IRS penalty relief procedures, penalties can be abated where the taxpayer shows that the failure was due to reasonable cause and not willful neglect. Reasonable cause covers illness, death in the family, natural disasters, reliance on professional advice in defined circumstances, and other qualifying events.
• Statutory Exceptions: Specific IRC provisions carve out penalty relief for defined categories, including certain tax return preparer situations, military service, and disaster area declarations.
• Interest Abatement: Interest can be abated in narrow circumstances under IRC § 6404(e) for unreasonable IRS error or delay.

Penalty abatement requests are filed in writing through Form 843 or a written letter, with supporting documentation. The IRS reviews requests case by case, and denials can be appealed through the IRS Office of Appeals.

Collection Enforcement Actions We Reverse or Prevent

The resolution mechanisms above address the underlying liability. This section addresses the enforcement actions the IRS takes to collect on that liability. Reversing or preventing enforcement is often the first-order need in the case.

Federal Tax Liens

A Notice of Federal Tax Lien (NFTL) is the IRS's public claim on a taxpayer's assets, filed under IRC § 6323 in the county of residence or business. The lien attaches to all property and rights to property, appears in public records, and is used by lenders and background check services. It can block real estate transactions, refinancing, and certain business financing.

• Withdrawal under IRC § 6323(j): The IRS withdraws the NFTL where the withdrawal facilitates collection or where the filing was premature. Withdrawal removes the public record.
• Subordination under IRC § 6325(d): The IRS subordinates its lien position to a specific creditor where doing so facilitates collection of the underlying tax.
• Discharge under IRC § 6325(b): The IRS discharges specific property from the lien where the taxpayer sells the property, and either pays the lien in full from proceeds or shows the remaining property is sufficient security.
• Release under IRC § 6325(a): After the liability is paid or becomes unenforceable, the IRS releases the lien.

Lien work is often the trigger event for engagement. A pending real estate transaction, refinance, or credit application forces immediate action on a lien that has been sitting quietly for years.

Levies and Wage Garnishments

A levy is the IRS's active seizure of property under IRC § 6331. It is the enforcement action clients most often want reversed immediately, and the timeline for release is short. Bank levies are the most time-sensitive category. When the IRS serves a levy on a bank, the bank holds the funds for 21 days before remitting them to the IRS. That 21-day window is the release window, and it closes without extension.

Wage garnishments operate on a different rhythm. Under IRC § 6331(e), they continue as continuous levies until released or paid, with the IRS applying a statutory exempt amount, based on filing status, that is often far below the taxpayer's actual living expenses.

For businesses, the IRS can also levy accounts receivable, directing customers to pay the IRS rather than the business, which often causes immediate operational damage. The IRS releases levies under IRC § 6343 when the levy would create economic hardship, when an installment agreement is in place, when an OIC is pending, when a CDP request has been filed, or when the collection statute has expired.

Collection Due Process Hearings

Collection Due Process (CDP) is the taxpayer's statutory right to independent Appeals review of proposed collection actions under IRC §§ 6320 (lien) and 6330 (levy). CDP is the highest-leverage collection procedural mechanism the taxpayer has. It stops enforcement, forces Appeals review, and preserves the right to Tax Court review of the collection action.

• Letter 3172: Trigger a 30-day CDP request window after the NFTL is filed.
• LT11, Letter 1058, and CP90: Trigger a 30-day CDP request window before the IRS can levy.
• Form 12153: The written request that initiates the CDP hearing.
• Impartial Appeals review: CDP hearings are held with an Appeals Officer who has not previously worked the case.
• Collection alternatives: Installment agreements, OICs, and other alternatives can be raised for the first time at the CDP hearing.
• Tax Court jurisdiction: A taxpayer who disagrees with the CDP determination has a 30-day window to petition the United States Tax Court under IRC § 6330(d).

Passport Revocation

Under IRC § 7345, the IRS certifies "seriously delinquent tax debts" to the State Department, which can then deny, revoke, or limit the taxpayer's passport. The threshold amount is adjusted annually for inflation and is set in the mid-to-high five figures. Certification excludes debts under an installment agreement, in CNC status, being addressed through a pending OIC or CDP hearing, or subject to innocent spouse relief.

Passport certification is often the enforcement action that finally brings taxpayers into representation, particularly for individuals whose work or family circumstances require international travel. 

The remedy is the same set of resolution mechanisms the negotiation would have used anyway — installment agreement, OIC, CNC status, or CDP hearing — with additional urgency on the timeline. Certification is reversed when the underlying condition changes.

What a Successful IRS Negotiation Looks Like

Collection resolution outcomes range across a spectrum. A properly handled case aims at the combination of financial and procedural results that the specific facts support.

• Streamlined installment agreement in place: Manageable monthly payments locked in for balances under $50,000 with no ongoing collection risk.
• Standard IA at Collection Financial Standards: Payment terms based on actual disposable income after Form 433 disclosure.
• Partial Payment IA: Monthly payments based on the taxpayer’s ability to pay that will not retire the liability before the CSED.
• Accepted OIC: Settlement of the tax debt at Reasonable Collection Potential, resolving the liability for less than the full amount owed.
• CNC status granted: Active collection suspended for taxpayers whose financial position genuinely does not support payment.
• Penalty abatement: Removal of failure-to-file, failure-to-pay, and accuracy penalties under FTA or reasonable cause standards.
• Lien withdrawal or subordination: Public record cleared to allow real estate transactions or credit access.
• Levy released: Active bank or wage levies removed before permanent seizure of funds.
• Passport certification reversed: IRC § 7345 certification withdrawn through resolution of the underlying liability.
• CSED reached: Statutory expiration of the collection statute where circumstances allow.

None of these outcomes arrives on its own. Each one follows from the specific procedural work and financial analysis we build into the case from the first meeting.

Ask Wiggam Law

Call Wiggam Law to Start Your Atlanta IRS Negotiation

The IRS collection process moves on the IRS's calendar. Balances grow every month, enforcement notices issue automatically, and the procedural windows for CDP hearings, levy release, and other collection alternatives close on schedule regardless of the taxpayer's circumstances. We represent clients at every stage these cases reach:

• Installment agreement negotiation for balances of all sizes, including streamlined, standard, and partial payment agreements
• Offer in compromise preparation and negotiation with Reasonable Collection Potential analysis and financial disclosure
• Currently Not Collectible status for taxpayers whose financial position does not support payment
• Penalty abatement through First Time Abate and reasonable cause standards
• Lien withdrawal, subordination, and discharge to clear title for real estate transactions and financing
• Levy release and wage garnishment removal on active enforcement
• Collection Due Process hearings to force Appeals review of proposed collection actions
• Passport revocation reversal under IRC § 7345
• Innocent spouse relief under IRC § 6015
• Coordinated Georgia Department of Revenue negotiation for parallel state exposure

Tax law is the only thing we do. Every attorney on staff handles IRS and Georgia Department of Revenue cases daily, and our team includes former IRS Revenue Officers whose experience inside the agency informs how we defend our clients on the outside. That focus is why Atlanta taxpayers trust us with collection matters that must be negotiated correctly the first time.