Our Experienced Tax Professionals Are Here to Help You
The IRS filed a Notice of Federal Tax Lien against your business address, and your CPA says they don’t handle collections. Your payroll tax liability keeps growing, your accountant suggested an Offer in Compromise without explaining trust fund recovery penalties, and the Georgia Department of Revenue filed a state lien and is threatening to seize your business accounts.
You need a tax attorney who litigates IRS cases, not someone who files returns and hopes the problem resolves itself.
Wiggam Law focuses exclusively on tax law. We don’t handle bankruptcy, personal injury, or estate planning alongside tax matters. Tax defense is the only thing we do, which means our Atlanta business tax attorneys build strategies around IRS procedures, Collection Due Process hearings, and penalty abatement, not generic advice pulled from a practice area menu.
When the IRS issues a levy or files a lien, you need someone who knows how to challenge collections, not someone who treats tax law as a side practice.
Talk to an Atlanta Tax Attorney Before the IRS Takes Action
The difference between tax advice and tax defense becomes clear when the IRS moves from notices to enforcement.
If you’ve received a levy notice or tax lien, time matters. Speak directly with a tax defense attorney and understand your options before enforcement escalates. Call now to discuss your business tax case with our Atlanta office, or reach out to our Norcross location.
A business tax attorney can help. At Wiggam Law, our Atlanta business tax lawyers are ready to assess your situation and help you find a solution based on your unique needs and priorities.
Why Choose Wiggam Law for Business Tax Defense in Atlanta
Tax law isn’t one of many services at Wiggam Law. It’s the only thing we do.
That focus shapes how we approach IRS collections, state tax disputes, and audit representation. While general practice attorneys juggle multiple case types, our team focuses solely on tax resolution strategies and the procedural rules that determine whether the IRS can seize business assets or garnish accounts.
Strategic advocacy over generic reassurance
The IRS doesn’t negotiate based on sympathy. They follow procedures, and effective tax defense requires understanding those procedures better than the revenue officer assigned to your case.
Our IRS tax lawyers in Atlanta build strategies around IRS collection alternatives, statute of limitations issues, and penalty abatement criteria—not platitudes about understanding your stress.
Local knowledge of Atlanta and Georgia tax systems
Our Atlanta office at 1275 Peachtree Street NE handles both federal and Georgia state tax matters. The Georgia Department of Revenue operates under different collection procedures than the IRS, and state tax liens require separate defense strategies.
Our tax lien lawyers in Atlanta represent metro-area businesses from Buckhead to Midtown, addressing payroll tax liabilities, sales tax audits, and withholding tax disputes that affect Georgia businesses.
Direct communication about case strategy
Tax defense requires understanding what the IRS will accept, what they’ll reject, and which collection alternatives fit your financial situation.
We explain installment agreement qualifications, Currently Not Collectible status requirements, and Offer in Compromise criteria without sugarcoating the timeline or the IRS’s calculation methods. Some cases resolve through penalty abatement, others require Collection Due Process hearings, and a few demand federal court litigation.
Business tax cases at Wiggam Law receive the same level of attention whether the liability is $50,000 or $2.5 million. We don’t prioritize high-dollar cases over smaller liabilities because the IRS uses the same collection tools regardless of the amount owed.
Common Business Tax Challenges Facing Atlanta Companies
Business tax liabilities create legal problems that standard accounting services don’t resolve. CPAs prepare tax returns and provide compliance advice, but when the IRS files a Notice of Federal Tax Lien or issues a Notice of Intent to Levy, the case moves beyond accounting into enforcement defense territory. These challenges require attorneys who understand IRS procedures and collection defense strategies.
Trust Fund Recovery Penalty Holds Business Owners Personally Liable
The trust fund recovery penalty bypasses corporate and LLC liability protections, holding business owners and officers personally responsible for unpaid payroll taxes. The IRS treats withheld employee taxes as trust funds that belong to the government, not the business. When a company fails to remit those withholdings, the IRS pursues individual officers who had authority over financial decisions.
This penalty attaches to personal assets, not just business property. The IRS interviews employees, reviews bank signature cards, and examines financial records to identify responsible persons.
Corporate structure doesn’t protect against trust fund penalties, and the IRS routinely assesses these liabilities against multiple individuals within the same company. Defense requires challenging the IRS’s determination of responsibility before the penalty becomes final.
Payroll Tax Liabilities Trigger Aggressive Collection Action
Payroll tax debt receives priority treatment from the IRS. Unlike income tax liabilities, which follow standard collection procedures, payroll tax cases often escalate quickly to levies and liens. The IRS views unpaid payroll taxes as theft of employee withholdings, so, IRS revenue officers assigned to these cases are aggressive in pursuing collection of the tax debt.
Businesses struggling with cash flow often fall behind on quarterly payroll tax deposits, creating compounding liabilities that include penalties and interest.
The IRS rejects Offers in Compromise for businesses with ongoing payroll tax obligations. Strategic defense focuses on Collection Due Process hearings, penalty abatement for reasonable cause, and installment agreements or Currently Not Collectible status to prevent levies while the business stabilizes.
Tax Liens Damage Business Credit and Block Financing
A Notice of Federal Tax Lien becomes public record once filed, signaling to lenders that the IRS holds a priority claim against the business’s assets. Tax liens attach to all property owned by the business, including accounts receivable, equipment, real estate, and future assets acquired after the lien filing. That priority position makes refinancing difficult and blocks most commercial loans.
Get Strategic Tax Defense — Not Generic Advice
Work with an Atlanta business tax attorney who handles IRS collections, penalty defense, and litigation—not just filings. Schedule a confidential consultation today.
Tax Audits Require Specialized Documentation and Legal Strategy
IRS audits of business returns examine income reporting, expense deductions, and compliance with tax code requirements. The IRS audit process begins with document requests and can expand to include examinations of multiple tax years.
Revenue agents review bank statements, invoices, contracts, and internal accounting records to verify reported figures. Audit representation goes beyond providing documents. It includes challenging proposed adjustments, negotiating with revenue agents, and appealing unfavorable determinations.
International Tax Compliance Failures Carry Severe Penalties
Businesses with foreign bank accounts, overseas operations, or international transactions are subject to reporting requirements under the FBAR and FATCA regulations. Failure to report foreign financial accounts can trigger penalties that exceed the account balance.
The IRS treats international tax compliance as a priority enforcement area, and voluntary disclosure programs offer pathways to resolve unreported foreign income or accounts.
Syndicated Conservation Easement Audits Target Tax Deductions
The IRS challenges syndicated conservation easement investments where taxpayers claimed charitable deductions based on inflated land valuations. These audits involve complex appraisal disputes, partnership examination procedures, and listed transaction penalties.
The IRS’s position on conservation easements has evolved to disallow deductions that exceed the investor’s basis by large multiples.
Who Needs an Atlanta Business Tax Attorney
Tax liability doesn’t discriminate by business size or structure. Sole proprietors, partnerships, S-corporations, and C-corporations all face IRS collection action when tax obligations go unpaid. The need for legal representation depends on the type of tax problem, not the company’s revenue or employee count.
Independent Business Owners Facing Collections
Business owners who operate restaurants, retail stores, professional services, or contracting companies often prioritize payroll and operating expenses over quarterly estimated tax payments. That decision creates tax liabilities that compound with penalties and interest. When the IRS issues a Notice of Intent to Levy or files a tax lien, the business owner faces collections that threaten bank accounts, customer payments, and business property.
Independent business owners need representation that addresses immediate collection threats while building long-term compliance. The IRS offers installment agreements, but acceptance requires current filing status and ongoing compliance with estimated tax payments. Our Atlanta office works with business owners to structure payment plans, request Currently Not Collectible status, or pursue an Offer in Compromise when financial hardship prevents full payment.
Professionals with Self-Employment Tax Issues
Attorneys, doctors, dentists, insurance agents, and real estate professionals who are self-employedoperate as independent contractors face quarterly estimated tax obligations. Missing those payments creates underpayment penalties and daily compounding interest on top of the tax owed. Self-employment tax adds 15.3% to the income tax obligationSocial Security and Medicare, and failure to pay estimated taxes triggers additional penalties.and daily compounding interestfor Social Security and Medicare, and failure to pay estimated taxes triggers interest that compounds daily.
Professionals who bill clients directly often lack payroll withholding, making tax compliance a manual process. When work demands override tax planning, liabilities accumulate quickly. Our representation addresses both the immediate collection issue and the underlying compliance problem to prevent future liabilities.
Companies with Payroll Tax Debt
Businesses that employ workers must withhold income taxes, Social Security, and Medicare taxes from paychecks and remit those amounts to the IRS quarterly. Cash flow problems sometimes force business owners to delay those deposits, creating payroll tax liabilities that trigger trust fund recovery penalties. The IRS pursues these cases aggressively because withheld taxes belong to employees, not the business.
Payroll tax defense requires understanding trust fund penalty procedures, responsible person determinations, and collection alternatives that keep the business operational. The IRS rejects some installment agreement requests for businesses with payroll tax debt, making strategic negotiation essential to avoid levies.
FAQ for Atlanta Business Tax Attorneys
A filed Notice of Federal Tax Lien becomes public record, attaches to all business property, and damages credit worthiness. The lien gives the IRS priority over most other creditors, making refinancing and asset sales difficult.
Lien subordination, discharge, or withdrawal requires meeting specific IRS criteria and submitting detailed applications. Ignoring the lien doesn’t make it go away, and the IRS can maintain liens for ten years while pursuing other collection actions simultaneously.
The trust fund recovery penalty makes business owners, officers, and anyone with authority over financial decisions personally liable for unpaid payroll tax withholdings. Corporate or LLC structures don’t protect against this penalty because the IRS treats withheld employee taxes as trust funds that responsible persons must remit.
The penalty equals 100% of the unpaid trust fund portion and can attach to personal assets, bank accounts, and wages. Defense requires challenging the IRS’s responsible person determination before the penalty becomes final.
The collection statute expiration date gives the IRS ten years and thirty days from the assessment date to collect tax liabilities. Certain actions extend that period, including Offer in Compromise applications, bankruptcy filings, and Collection Due Process hearing requests.
The IRS can renew collection efforts at any point during the ten-year window, and some taxpayers mistakenly believe that avoiding contact runs out the clock. The statute provides a deadline, but the IRS pursues collection aggressively within that timeframe.
Business tax cases involve payroll tax obligations, trust fund penalties, and ongoing compliance requirements that personal tax liabilities don’t carry. The IRS treats business tax debt as a priority collection matter, particularly in payroll tax cases.
Business owners face personal liability through trust fund recovery penalties, and state tax authorities pursue business tax debt through separate enforcement actions. Defense strategies must address both federal and state tax obligations while maintaining business operations.
Yes, we immediately contact the IRS to negotiate a collection hold to prevent IRS levies or liens and take proactive action to prevent further collection actions. If a levy or garnishment is already in place, we negotiate with the IRS to have that action removed. Collection Due Process hearing requests filed within 30 days of notice prevent levy action during the hearing. Installment agreement applications sometimes delay collection while under IRS review. Revenue officers assigned to cases can continue collection efforts unless a specific procedure triggers an automatic hold. Strategic representation focuses on pursuing collection alternatives that prevent enforcement while resolving the underlying liability.
The IRS typically examines three years of tax returns during audits, but if you omit more than 25% of your income, it can extend that period to six years. The examination period can cover multiple years simultaneously, requiring documentation and records for each year under review. Audit expansion occurs when initial findings suggest unreported income or questionable deductions across multiple years. Some industries face higher audit rates, and certain deductions trigger automated reviews regardless of the taxpayer’s compliance history.
A Final Notice of Intent to Levy provides 30 days to request a Collection Due Process hearing before the IRS seizes assets. Filing a timely CDP request prevents levy action while the hearing proceeds. The notice indicates that the IRS has exhausted preliminary collection steps and moved to enforcement. Ignoring the notice allows the IRS to levy bank accounts, garnish accounts receivable, and seize business property without further warning. Contact a tax attorney immediately to evaluate collection alternatives and preserve hearing rights.
Strategy Beats Sympathy When Facing IRS Collections
The IRS revenue officer assigned to your business tax case follows procedures, not emotions. They calculate reasonable collection potential, verify financial statements against bank records, and pursue enforcement when collection alternatives don’t meet IRS criteria.
Tax defense at Wiggam Law focuses on building strategies that address those procedures—Collection Due Process deadlines, penalty abatement qualifications, installment agreement requirements, and the documentation needed to support each collection alternative.
Tax law is the only thing we do. That focus means our Atlanta office concentrates on IRS collection defense, Georgia Department of Revenue disputes, and audit representation without juggling unrelated practice areas. Call now to discuss your business tax case.
The IRS doesn’t pause collections while you research options.
Stop IRS Collections Against Your Business
Call now to discuss your case with an Atlanta tax attorney and take the first step toward resolving your tax liability. Call Wiggam Law today.