IRS Tax Attorney Serving Edison, NJ
A business tax problem can involve the company, its owners, or both. An individual tax matter may involve missing returns, a disputed assessment, unpaid tax debt, or IRS collection that has already started.
Todd S. Unger represents individuals and businesses in Edison and throughout Middlesex County in IRS and state tax matters. The first step is identifying who owes the tax, which periods are involved, what the agency is asking for, and whether a response or appeal deadline is approaching.
Federal Tax Representation for Edison Individuals and Businesses
IRS problems can begin in very different ways. A taxpayer may receive an audit notice, a business may fall behind on payroll deposits, an individual may have several unfiled returns, or the IRS may already be threatening a levy or filing a federal tax lien.
Those situations should not be treated as though they require the same solution. The correct response depends on whether the issue concerns the amount of tax, filing compliance, payment ability, an examination, active collection, or potential personal liability.
Todd S. Unger helps clients review notices, tax periods, records, and procedural posture before deciding which IRS issue to address first.
IRS Tax Problems We Help With
The firm assists Edison taxpayers with federal tax controversies involving audits, collection, unfiled returns, tax liens, payment problems, and penalties.
Help responding to IRS examinations, document requests, proposed adjustments, and disputed audit findings.
Address missing returns, substitute-for-return assessments, and unresolved federal tax balances.
Respond to collection involving bank accounts, wages, accounts receivable, or other property.
Review lien filings and available procedures involving property, financing, and collection.
Evaluate payment arrangements when an assessed balance cannot be paid immediately.
Review whether assessed penalties may qualify for administrative relief or another challenge.
Payroll Taxes and Potential Personal Liability
Unpaid employment taxes require careful review because certain individuals may face a Trust Fund Recovery Penalty.
The IRS does not automatically impose the penalty on every business owner. The IRS considers whether an individual was responsible for collecting, accounting for, or paying the trust-fund taxes and willfully failed to do so.
The trust-fund portion generally includes withheld federal income tax and the employees’ share of Social Security and Medicare taxes. It is not the same as the entire employment-tax balance, including the employer’s matching share.
Relevant records may include payroll returns, deposit records, bank-signature authority, checks, account records, and information showing who made decisions about tax deposits and creditor payments.
Personal liability depends on the facts. A title such as owner, officer, or manager does not by itself determine TFRP liability. Actual authority, responsibility, and conduct matter.
Learn more about payroll and employment tax representation.
Business Tax Problems May Involve More Than One Taxpayer
A business tax issue may involve the company, an owner, an officer, or several parties with different exposure. Payroll taxes are one example, but business audits, missing returns, collection against business assets, and disputed tax assessments can also require separate analysis.
Keep the business’s tax records separate from personal records while identifying issues that affect both. For an initial review, note the legal entity, tax type, tax periods, assigned IRS employee, and upcoming response date.
If the IRS has requested financial information from the business, identify the specific form or records requested before responding.
Unreported Foreign Income or Missing Foreign-Account Filings
A foreign-account or income-reporting problem should not automatically be directed into a single disclosure program.
The IRS Criminal Investigation Voluntary Disclosure Practice addresses certain willful noncompliance and potential criminal exposure. Streamlined Filing Compliance Procedures are different and have their own eligibility requirements, including certification that the relevant failures resulted from non-willful conduct.
The appropriate approach depends on the facts, filing history, foreign accounts or income involved, prior filings, and whether the IRS has already begun an examination, investigation, or other enforcement activity.
Do not select a correction procedure based only on the program name. Obtain legal advice before making a willfulness or non-willfulness certification or submitting a voluntary disclosure.
When the IRS Requests Financial Information
Some collection cases require financial disclosure before the IRS will evaluate a proposed payment arrangement, hardship request, partial-payment arrangement, or other collection alternative.
The IRS may ask for information about income, expenses, bank accounts, investments, real estate, business assets, liabilities, and other financial information.
The correct financial statement depends on the taxpayer and collection procedure. Learn more about IRS Form 433 financial statements.
What to Have Ready for an Initial Review
When contacting the office, explain whether the matter is personal or business-related, identify the tax periods involved, and mention whether an IRS or state employee has been assigned. Include any approaching deadline.
For payroll matters, identify the business entity and affected quarters. For an individual collection matter, have the most recent balance and collection notice available.
About Todd S. Unger
Todd S. Unger, Esq. is a tax attorney whose practice focuses on federal tax controversy and disputes involving individuals and businesses.
His practice includes IRS audits, payroll and employment tax matters, tax debt, federal tax liens, levies, unfiled returns, penalty disputes, and other federal tax controversies.
Tax Representation for Edison and Middlesex County
Many federal tax matters can be handled by phone, email, secure document exchange, and virtual meeting. This can be especially useful when the case involves tax notices, transcripts, payroll records, returns, and other documents that can be reviewed electronically.
You can confirm consultation arrangements and any in-person meeting location when scheduling. This page describes representation available to Edison taxpayers and does not imply that the firm maintains a physical office in Edison.
Edison Tax Attorney FAQs
Discuss Your Edison Tax Matter
Contact Todd S. Unger’s office to discuss an IRS audit, payroll tax problem, collection notice, tax debt, unfiled return, federal tax lien, levy, or other tax controversy.
If an IRS deadline, levy, payroll tax interview, or other urgent issue is approaching, mention that when requesting the consultation.