Representation built around the action you are facing
An IRS attorney helps you understand the legal issues in a tax matter, respond to agency action, and evaluate available administrative or court procedures. The right starting point depends on what the IRS is doing now, not simply on the amount shown on a letter.
Margolies Law Office represents individuals and businesses in IRS matters from its Dallas office. We review the notice or collection action, identify time-sensitive issues, and explain the scope of representation that may be appropriate.
Key Takeaways
- The right starting point for IRS help depends on the specific action being faced (levy, revenue officer contact, audit, adjustment, or Notice of Deficiency), not the amount on the letter.
- Form 2848 authorizes an eligible practitioner to represent a taxpayer before the IRS for specified matters and periods.
- Levy release does not cancel the underlying tax debt, and requests for relief are not guaranteed approval.
- Attorneys, CPAs, and enrolled agents may all represent taxpayers before the IRS, but Tax Court representation requires separate admission to that court.
- Attorney-client privilege and a limited tax-practitioner privilege can protect certain communications, but neither offers blanket protection, and the tax-practitioner privilege does not apply to criminal tax matters.
Start by identifying the current stage
What you received or experienced : A frozen bank account or wage levy
What needs review first : The levy type, relevant dates, affected tax periods, and possible release grounds
Related assistance : Bank levy or wage-levy representation
What you received or experienced : Contact from a revenue officer
What needs review first : The request, response date, filing history, and financial information needed
Related assistance : Revenue-officer representation
What you received or experienced : An audit letter or records request
What needs review first : The years and issues under examination, the requested records, and the deadline
Related assistance : Audit representation
What you received or experienced : A proposed tax adjustment
What needs review first : Whether the adjustment is correct and what response or appeal rights are available
Related assistance : Dispute review and IRS appeals
What you received or experienced : A Notice of Deficiency or CDP determination
What needs review first : The particular notice and deadline for any court petition
Related assistance : Evaluation of court options
| What you received or experienced | What needs review first | Related assistance |
|---|---|---|
| A frozen bank account or wage levy | The levy type, relevant dates, affected tax periods, and possible release grounds | Bank levy or wage-levy representation |
| Contact from a revenue officer | The request, response date, filing history, and financial information needed | Revenue-officer representation |
| An audit letter or records request | The years and issues under examination, the requested records, and the deadline | Audit representation |
| A proposed tax adjustment | Whether the adjustment is correct and what response or appeal rights are available | Dispute review and IRS appeals |
| A Notice of Deficiency or CDP determination | The particular notice and deadline for any court petition | Evaluation of court options |
Keep the entire notice rather than relying on a summary of it. The IRS identifies different appeal opportunities for different letters, including examination, levy, and lien notices.
What changes when you retain representation?
Representation begins with an agreed scope of work and the necessary authorization. Form 2848 is commonly used to authorize an eligible practitioner to represent a taxpayer before the IRS for specified matters and periods.
Depending on the engagement, the work may include reviewing account information, evaluating legal issues, preparing responses, communicating with IRS personnel, and presenting a proposed resolution. We also explain what information we need from you and which decisions remain yours to make.
Hiring a representative does not mean every letter or obligation disappears. Continue keeping correspondence and share new notices promptly so deadlines and developments can be reviewed.
If the IRS is collecting
Collection cases require attention to both the immediate action and the underlying tax balance. For example, a bank levy may create an urgent need to request release while the broader matter requires a filing review, a dispute about the assessment, or evaluation of payment options.
The IRS describes several grounds for levy release, including payment of the liability and qualifying economic hardship. Release does not by itself cancel the tax debt, and a request for relief does not guarantee approval.
Learn more about bank levy release, wage garnishment, and revenue-officer representation.
If the IRS is examining or adjusting a return
An examination and a collection case are different procedures. In an examination, the work centers on the return, supporting records, the IRS’s questions, and whether proposed changes are supported.
Our approach is to understand the request, organize the relevant facts, and respond appropriately. If a disagreement remains, we review the notice and available next steps rather than assume that every dispute follows the same appeal path.
Read about audit representation and IRS appeals.
Choosing an attorney, CPA, or enrolled agent
Attorneys, CPAs, and enrolled agents may all represent taxpayers before the IRS when eligible and properly authorized. Tax Court representation requires separate admission to that court; an admitted nonattorney practitioner may also represent taxpayers there.
Choose a professional whose actual experience fits the issue. A matter involving legal disputes, litigation, or potential criminal exposure may call for legal advice, while accounting, return preparation, and administrative representation may involve a CPA or enrolled agent.
At Margolies Law Office, Andrew Margolies handles the firm’s IRS legal work, while Jennifer Margolies works as an Enrolled Agent and case manager. Meet the firm’s team.
Confidentiality and legal advice
Attorney-client privilege may protect confidential communications made for legal advice, subject to applicable requirements, exceptions, and waiver. It is not a blanket protection for every document or interaction; ask about confidentiality before sending sensitive information.
A limited tax-practitioner privilege can apply to qualifying tax-advice communications in noncriminal IRS matters and certain noncriminal federal-court tax proceedings. It does not provide the same protection for criminal tax matters.
Preparing for the first discussion
Have the following available if you can:
- IRS correspondence: The complete notice, any attachments, and the envelope.
- Timeline: When the issue began and the next response date.
- Tax periods: The years or quarters involved.
- Prior responses: Copies of submissions or notes about earlier IRS contact.
- Related concerns: Missing returns, payment difficulties, or other unresolved tax matters.
Do not send Social Security numbers or financial account details through an initial contact form. The office can explain the appropriate process for exchanging sensitive records.
Discuss your IRS matter
Whether the immediate concern is a notice, an examination, or active collection, the next step is to understand the facts and available procedures. We offer a free, no-obligation consultation to discuss your situation.
This page provides general information, not legal advice. Using this website or submitting a contact form does not create an attorney-client relationship. Prior results do not guarantee a similar outcome.