Success Stories

Affordable Monthly Payments on $785,000 Payroll Tax Debt

The situation: Due to a cash flow crunch and economic downturn, a contract security guard company fell $785,000 behind on its 941 payroll taxes. The IRS threatened to assess a Trust Fund Recovery Penalty (TFRP) against the owner personally, and a Revenue Officer showed up in person with a Final Notice of Intent to Levy the business's bank accounts in 30 days.

What we did: We filed a Form 2848 (Power of Attorney) so we could step in with the local IRS Revenue Officer. The initial discussions were highly adversarial due to the nature of trust fund taxes, but we secured a collection hold to prevent the IRS from seizing any assets. Over the next 21 days, we reconstructed the business's payroll records so we could address two quarters of unfiled returns. Then, we filed a Form 433-B, Collection Information Statement, requested penalty abatement, and negotiated an affordable Partial Payment Installment Agreement (PPIA) based on the business's current cash flow.

The outcome: The business stayed open. The owner avoided personal liability for a TFRP. The IRS abated a portion of the late filing and payment penalties and approved an affordable monthly payment plan.

“When a Revenue Officer showed up at my company and asked to speak to the owner, I was very worried. Tim stepped in, became our advocate, and saved the business we have been building for many years.”

Where to go next:Help for payroll tax & TFRP cases

Defending a partner against a Trust Fund Recovery Penalty

The situation: The IRS had proposed a Trust Fund Recovery Penalty against the partner of a real estate company. The partner did not fit the criteria to be labeled as a responsible person and shouldn't have faced the penalty.

What we did: We successfully proved to the IRS that our client was not a responsible person in relation to the business's unpaid payroll taxes. Our TFRP defense convinced the agency to drop the penalties.

The outcome: The client avoided $87,000 in trust fund tax, penalties, and interest.

$114,000 settlement on a $265,000 IRS assessment for unfiled tax years

The situation: An independent real estate consultant had several years of unfiled returns, so the IRS generated a Substitute for Return (SFR) showing an inflated balance due of $265,000, and then they levied the client's bank account. With their funds frozen, the client couldn't pay their monthly living expenses and was worried about their financial stability and professional reputation.

What we did: Within 24 hours, we secured an emergency levy release to unfreeze the funds in the client's bank account. Then, we filed five years of accurate 1040 returns to replace the SFR, reducing the tax liability by $20,000. After assessing the client's Reasonable Collection Potential, we put together an Offer in Compromise package backed by extensive medical and financial documentation and negotiated a $114,000 settlement.

The outcome: The IRS accepted a $114,000 settlement and released all tax liens.

“My tax debt issue has been resolved, and I am so relieved.”

Where to go next:Help with tax debt

Catching up on 10 Years of unfiled tax returns

The situation: The client hadn't filed taxes for 10 years, and IRS notices were threatening automated collection actions. The client was worried about legal consequences and threats to their bank accounts and Social Security benefits.

What we did: We executed a Power of Attorney to protect the client from direct IRS contact, and then we filed their back taxes using wage and income transcripts from the IRS. We applied for penalty abatement to reduce the accrued failure-to-file and failure-to-pay penalties and negotiated an Installment Agreement with monthly payments based on the client's budget.

The outcome: The client got real relief. They had monthly payments they could afford, and they didn't need to worry about the IRS coming after their assets.

“After 10 years of not filing my taxes, I was terrified to check my mail every day. Tim Hart took complete control of the situation, got me compliant, removed the penalties, and set up a monthly payment I could actually afford. I can finally sleep again.”

Where to go next:Help with unfiled tax returns

Helping a NY taxpayer with unfiled IRS tax returns

The situation: A client from Saratoga Springs owed the IRS $32,000 related to several years of unfiled tax returns.

What we did: We filed correct tax returns for the client and negotiated a payment plan with the IRS.

The outcome: Filing compliance, affordable monthly payments based on the client's budget, and protection from IRS collections.

Settling payroll and income tax for less than 70% owed

The situation: A client from Albany owed over $600,000 in payroll and income tax to the IRS. They couldn't afford to pay it, but the IRS had already denied an offer in compromise request from their previous attorney for $325,000.

What we did: We took the case to Appeals, and after hearing our arguments, the IRS Appeals Division Officer approved an offer in compromise of approximately $165,000

The outcome: Reduced a $600,000 tax debt to $165,000

$500 settlement on a $48,000 NYS tax liability

The situation: The client owed NYS $48,000 in tax, interest, and penalties due to unfiled returns from 1990 to 1999. He was no longer living in New York, and was unable to pay the tax debt due to mental health concerns.

What we did: We proved to the DTF that the client could not pay in full and negotiated an offer in compromise of just $500.

The outcome: The DTF accepted a $500 settlement on the $48,000 tax liability.

Here are more examples of how we've helped clients settle tax debt:

Settled a $130,000 IRS tax liability for $32,750 through effective tax administration, even though the client had substantial assets.

Helped a client in Brooklyn settle $120,000 in IRS payroll taxes for $49,500

Stopping Collections for Hardship on a $199,000 Tax Debt

The situation: A retired consultant owed $199,000 in back taxes but was now on a fixed income and unable to pay. The IRS filed a lien against their assets, making them extremely worried about losing their home.

What we did: After analyzing the client's finances and tax transcripts, we advised them to pursue Currently Not Collectible (CNC) status. They wouldn't need to pay anything, and the IRS would stop all collection activity. Because the client was on a fixed income, their account would stay in CNC status until the Collection Expiration Date (CSED), meaning they wouldn't have to pay anything. We negotiated IRS hardship relief by proving that the client's expenses exceeded their income.

The outcome: The IRS stopped all collections. The client didn't have to pay anything.

“Tim understood our tax issue, and did not judge us. He made the IRS look at us and our financial reality, and stopped the collection enforcement against us.”

Where to go next:Help with IRS hardship (currently not collectible status)

Partial payments of $60,000 on a $285,000+ tax debt

The situation: A client from Manhattan owed about $285,000 total to the NYS DTF and the IRS from a six-year period. They couldn't afford to pay in full and were worried about collection actions.

What we did: We negotiated a Partial Payment Installment Agreement with both the IRS and NYS DTF. In total, the client would only have to pay $60,000 to both tax agencies, saving them approximately $215,000 plus significantly reducing the interest paid over the payment plan.

The outcome: Settled a $285,000 tax debt for just $60,000 in payments.

And here's how we've helped other clients with partial payment agreements:

A construction contractor from Manhattan – saved more than $25,000 with a partial payment plan

Client from Plattsburgh – negotiated a partial payment plan for $15,000 on an $88,000 income tax debt

Client from Utica – set up payments on a $25,000 partial payment installment agreement, even though he earned over $120,000 per year, owned a home, and had $25,000 in retirement savings

Where to go next:Get help with IRS installment agreements

Reducing a $500,000 sales tax assessment to $100,000

The situation: After selling their retail liquor store, our client was hit with a New York State sales-tax audit. Instead of using the store's actual sales records, the state estimated what it thought the store should have sold based mainly on its square footage, and assessed $500,000 in sales tax plus penalties and interest. The client was facing personal liability risk for sales tax on a business they didn't even own anymore.

What we did: We filed a formal request for audit reconsideration, then rebuilt the picture the state had ignored with supplier invoices, verified financial records, and actual sales documentation to show why a square-footage estimate badly overstated real sales. We negotiated directly with the New York sales-tax auditors to challenge the methodology itself.

The outcome: New York agreed to drop the arbitrary assessment and reduced the assessment from $500,000 to $100,000, and the client paid in full to close the case.

“When New York State handed us a $500,000 sales tax bill based on the size of our store, we thought we were ruined. Tim Hart challenged the state's calculations, brought the bill down to $100,000, and finally gave us our lives back.”

Where to go next:Help with NYS DTF sales tax audits

Protecting a Client From a NY Driver's License Suspension

The situation: A self-employed sales representative accumulated $38,500 in unpaid New York State income taxes over several years. Because the debt exceeded the $10,000 statutory threshold, the NYS DTF issued a tax warrant and notified the Department of Motor Vehicles (DMV) to initiate an automatic suspension of the client's driver's license under NY Tax Law § 171-v. The client received an urgent 60-day notice from the NYS DMV stating their driver's license would be suspended, which would prevent them from traveling to client meetings and performing their job.

What we did: We challenged the license suspension and negotiated a formal Deferred Payment Agreement (DPA). We also provided a comprehensive financial disclosure to the state to ensure the payments fit with our client's cash flow.

The outcome: The NYS DTF rescinded the driver's license suspension order. The client was able to make affordable monthly payments without worrying about collection risks.

“New York State was about to suspend my driver's license over past tax debt, which would have cost me my job. Tim Hart stepped in, set up a state payment plan, and saved my license.”

Where to go next:Help with DTF tax warrants and license suspensions

Clearing a decades old tax debt based on state residency

The situation: In 1992, our client sold a home in New Jersey. Because he owned a rental property in New York, the NYS DTF believed that he was a New York state resident so they initiated an audit and levied state taxes on him for the sale of the New Jersey house. The client ignored the audit notices, but about 20 years later in 2012, he approached us for help.

What we did: We re-opened the case and proved to the state that our client was not a resident of New York when he sold the house in New Jersey in 1992. The State agreed and wiped out his full tax debt.

The outcome: The client got complete relief from a $59,000 NYS tax liability.

Filing late FBARs & resolving offshore reporting noncompliance

The situation: The client had inherited several foreign bank accounts, but they didn't know they needed to file a Foreign Bank Account Report (FBAR) until they received a notice from their foreign bank explaining that their details were going to be shared with the IRS under the Foreign Account Tax Compliance Act (FATCA). The client also had unreported passive income from the foreign accounts. They were concerned about FBAR penalties for the missed filings and the risk of tax-evasion allegations relating to the unreported income.

What we did: We evaluated the foreign financial account records and the client's tax returns under attorney work-product and legal consultation confidentiality to determine if the failure to file was willful or non-willful. Based on the facts of the case, we determined that the conduct was non-willful and that the Streamlined Domestic Offshore Procedures were the appropriate compliance path. We amended three years of tax returns to include the unreported income, filed six years of FBARs, and prepared the required non-willfulness certification describing the client's background, education, and lack of willful intent.

The outcome: The IRS processed the submission under the non-willful streamlined framework and assessed the applicable 5% Title 26 miscellaneous offshore penalty, avoiding willful FBAR and civil fraud penalties.

“Unaware of the massive legal risks tied to my offshore accounts, I relied on Tim Hart’s IRS background for the targeted defense needed to fix the problem just in time”

Where to go next:Help with FBAR, FATCA, and international tax compliance

Full relief from a $110,000 tax debt due to a former spouse

The situation: The client owed $110,000 in IRS and NYS tax debt from a joint return she'd filed with her ex-husband. Despite the terms of the divorce decree, the ex-husband wasn't paying, and both the IRS and the NYS DTF were threatening to file tax liens and seize our client's bank accounts. She was facing financial ruin and didn't want to erode her life savings on a debt that wasn't her fault.

What we did: We filed a claim for Innocent Spouse Relief with the IRS and NYS. We explained that the tax debt was due to our client's ex-spouse's medical practice, which earned over $450,000 per year. Then, we presented extensive documentation (financial records, bank statements, legal correspondence, etc) to prove the ex-husband had total economic control over his business funds, and under IRC § 6015, it wouldn't be fair to hold our client responsible for the tax liability. When the ex-husband challenged the claim, we defended our position before IRS Appeals and secured full relief for our client.

The outcome: The IRS and NYS granted complete Innocent Spouse Relief, releasing the client from all liability for the $110,000 balance and transferring 100% of the financial burden to her former husband.

“When my ex-husband left me with $110,000 in unpaid joint taxes, I thought I was stuck paying his debt. Tim Hart fought his appeal, won Innocent Spouse Relief, and cleared my name completely.”

Where to go next:Get help with innocent spouse relief

Reducing an $85,000 audit assessment to under $7,600

The situation: The client came to us after receiving a Notice of Deficiency alleging they owed $85,000 in additional tax, interest, and penalties due to failing an audit. The IRS auditor had disallowed most of the deductions on the client's tax return, and the letter gave him 90 days to accept the assessment or challenge the government in federal court. He didn't agree with the audit's findings and was worried about the risk of tax liens, wage garnishment, and bank levies if the assessment was finalized.

What we did: We bypassed the audit division's rigid stance by filing a timely petition with the U.S. Tax Court. Then, we compiled tax records to validate the disputed income, deductions, and tax positions on the client's return. We negotiated directly with IRS Appeals Officers and District Counsel attorneys, leveraging legal precedents to challenge the audit's initial tax and penalty determinations. Ultimately, we settled the case without going to trial and reduced the client's assessment to under $7,600.

The outcome: Saved the client over $77,000. Reduced an $85,000 audit bill to under $7,600, which the client paid in full.

“When the IRS audited me and sent a letter saying I owed over $85,000, I was devastated. Tim Hart petitioned the U.S. Tax Court, fought the audit findings, and brought the final total down to less than $7,600. I couldn't be more relieved.”

Where to go next:How we help with IRS audit defense and audit reconsideration

Fast relief on IRS wage garnishment & NYS bank levy

The situation: The client owed $64,000 in NYS and IRS taxes due to financial hardship, but after ignoring back-tax notices for years, they arrived at work to discover that the IRS had served a continuous Form 668-W wage garnishment to their payroll department, taking over 70% of their take-home pay. To make matters worse, the NYS DTF simultaneously froze the client’s checking account, preventing them from accessing their remaining funds. The client’s rent check bounced, and they were unable to pay for food, utilities, or transportation to work.

What we did: We engineered an immediate emergency intervention with IRS Collections and the NYS Civil Enforcement Division based on severe economic hardship. Within the first 24 hours, we compiled financial documentation (Form 433-A, lease agreements, utility bills, and medical costs) to prove financial hardship. Then, we delivered formal releases to the client's payroll department and bank. The bank unfroze the funds within 24 hours, and the payroll department stopped the wage garnishment before the next pay period. Finally, we helped the client secure a Partial Payment Installment Agreement for $250 per month.

The outcome: Unfroze the client's bank account and released an IRS wage levy taking $2,200 from their monthly pay. Set the client up on affordable monthly payments of $250.

“I woke up to find my bank account frozen and most of my paycheck taken by tax levies. Tim Hart acted immediately, got my bank account unlocked in two days, and stopped the wage garnishment.”

Where to go next:Help with wage garnishments and levies

Stopping a tax levy on a client's retirement income

The situation: A retired client hadn't filed income tax returns for six years. The IRS assessed a balance and levied his retirement checks.

What we did: We filed the client's back taxes. Then, we proved to the IRS that he couldn't afford to pay anything on the tax debt.

The outcome: The IRS released the levy and didn't require the client to make monthly payments.

The Timothy S. Hart Law Group has successfully defended many clients against criminal charges, including:

• An attorney charged with filing false income tax returns – we got New York tax authorities to agree to a "no change" income tax report for all of his tax years.
• A business owner facing a criminal investigation related to sales tax – we negotiated a payment plan of $1,500/month on a $500,000 tax debt with no criminal charges filed.
• A CPA from White Plains facing charges of filing false tax returns – we settled the case with no criminal charges and no money owed.

To learn more, check out our tax evasion and criminal defense service page.