IRS Enforced Collections

  • Enforced Collection Activities
  • Liens
  • Levies
  • Criminal Referral
  • Audits
  • Penalty Assessments
  • Asset Seizures
  • Wage Garnishments
  • Substitute Return Filing
  • Civil Penalties
  • Transferee Liens
  • Transferee Assessments
  • Fraud Penalties
  • Failure to File Penalties
  • Failure to Pay Penalties
  • ​Summons

    Resolution Strategies

  • Installment Agreement
  • Partial Pay Installment Plan
  • Penalty Abatement
  • Interest Abatement
  • Collateral Agreement
  • Closing Agreement
  • Asset Substitution
  • Posting of Bond
  • Substitution of Sale Proceeds
  • Substitution of Value
  • Cash Deposit
  • Lien Subordination
  • Discharge of Property
  • Limitations Periods
  • Interest Redetermination
  • Application of Credits/NOLs
  • Interest/Penalty Suspension
  • Others as Codified in IRC

The 3:00 AM Wakeup

The most common suffering I hear from clients with tax problems is what I refer to as the "3:00 a.m. wakeup." The scenario usually involves falling asleep for several hours, then waking up panic stricken in the middle of the night. 

Mind wandering feverishly, sweating profusely, heart racing, wide awake you fitfully watch minutes turn into hours as you ponder how the IRS will contact you: Will today be the day? Will the IRS call, show up at my house, even come get me at work? Will they prosecute me criminally? Am I financially ruined?  How is my family going to be affected?  How can I fix this?  

After what seems like an eternity, night finally turns into another day and the panic turns into a tedious anxiety. Groggy from lack of sleep, you go about your daily routine suffering from an unending sense of worry and helplessness.

Wondering, how you ended up with all of these tax problems, you finish the day dreading another night of panic and wondering if this nightmare will ever end. Sound familiar? 

irs problems

Third, we develop a compliance plan and coordinate implementing the plan with the client and the IRS.  We could have the best plan of resolution in the world and it is worthless if the taxpayer is not presently compliant with all IRS filing and payment requirements. Finally, in employing these 3 prongs we are careful to evaluate which forum (IRS Collections, IRS Appeals, U.S. Tax Court, Federal District Court, etc.) is best for our client given the facts, circumstances, and procedural disposition.

James G. "Jimmy" McGee, Jr., Attorney

Managing Partner

First, we employ legal techniques to defend against IRS collections and give you some "breathing room" while we work the problem.  This generally involves defending against liens, levies, and other asset seizures and can often involve litigation or removal to appeals.

Second, we conduct a series of legal and financial analyses to determine the best plan for addressing the underlying problem.  It is somewhat simplistic to assume that one collection option (i.e. Offer in Compromise) works for every taxpayer; therefore, we evaluate a number of resolution techniques to determine which one, or which combination, will be most effective. (Imagine calling offensive plays for a football team...the more combinations of plays your team has available, the better chance the team has of finding a play, or combination of plays, that works against the defense. If the team only has one play, and that play doesn't work, the team is in trouble. Selecting Resolution Techniques is very similar.)  Once we have completed the analyses and developed the strategy, we then orchestrate implementation of the plan.


Yes. There are a number of legal and accounting techniques that can be utilized to resolve a tax deficiency.  However, each case is different; therefore, extensive analysis of the relevant facts, circumstances, and procedural disposition must be conducted before a gameplan can be developed and implemented.  Generally, we use a 3 pronged approach in working a tax case.  

McGee Tax Law's Tax Controversy Group

This group focuses on identifying all of the problem areas associated with a taxpayer's outstanding tax liability, while getting the taxpayer in a defensive posture against IRS collection activities.  Once the problem areas are identified, the focus is directed upon developing a collection alternative or challenging erroneous/invalid assessments. 


The answer to both of these questions depends on a number of factors including the amount of the alleged deficiency, the complexity of the accounting and legal issues, the number and type of assessments (tax, penalties, and interest), the procedural disposition of the case, the compliance history of the taxpayer, the need to employ third party professionals, etc.).  A small tax case take several months to complete, while a larger, more complex case can literally take years.  Likewise, legal fees can range from several thousand dollars into the tens (even hundreds) of thousands of dollars.  We try to spend considerable time evaluating the work to be done before we quote a fee for our services.  Generally, we attempt to structure a budget based on "worst" and "best" case scenarios.  Our goal is to obtain the results desired for the least amount of cost to our client.  We only bill our clients for services that we actually perform and each client is given detailed billing reports each month.  Our billings and fees are conducted in strict accordance with rules and procedures promulgated by the Mississippi Bar Association and Supreme Court.

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