Orlando Tax Attorneys

Work with an Experienced Orlando Tax Attorney to Avoid Unnecessary Tax Liability, Penalties, and Other Consequences

While all U.S. taxpayers must comply with the Internal Revenue Code and other federal Orlando tax law, taxpayers also have the right to ensure that they are not held liable for more than they owe. As the Internal Revenue Service (IRS) continues to audit individual and corporate returns and enforce tax debts through liens, levies, and other means, many taxpayers find themselves in need of an experienced Orlando, Florida, tax attorney. Criminal tax evasion investigations and other federal tax-related matters require experienced legal representation in the United States tax court as well.

Our Orlando tax lawyers represent individuals and organizations in all matters involving the IRS and IRS Criminal Investigation (IRS CI). We also provide representation for criminal tax fraud and tax penalties prosecuted by the U.S. Department of Justice (DOJ). If you (or your organization) are facing allegations or charges, or if you need to resolve a federal income tax filing or payment violation before it triggers federal scrutiny, we can use our experience to deal with the federal government effectively on your (or your organization’s) behalf.

Current IRS, IRS CI, and DOJ Enforcement Priorities (Updated 2024)

Within the area of federal tax compliance, the IRS, IRS CI, and DOJ currently have several enforcement priorities. While these are not the only issues that can lead to scrutiny, they are among the issues that are most likely to lead to invasive audits and investigations—and potentially to civil liability or criminal charges. These priorities include:

• Cryptocurrency Gains and Losses – As cryptocurrency maintains its mainstream push, federal authorities are seeking to vigorously enforce taxpayers’ reporting and payment obligations. Federal regulations classify cryptocurrency as property rather than currency, and all gains and losses from cryptocurrency transactions and trades are subject to timely and accurate reporting.
• Gaming and Gambling Gains and Losses – As gaming and gambling also continue to gain mainstream acceptance in Florida and other states, federal authorities are prioritizing income tax enforcement in this area as well. Gaming and gambling income from both legal and illegal activities are subject to reporting under the Internal Revenue Code.
• High–Income Taxpayers – In an effort to more quickly close the tax gap, the IRS is placing particular emphasis on targeting high-income taxpayers. Recent initiatives have targeted both filers and non-filer federal income taxes, with the IRS paying particular attention to tax preparation and tax planning strategies that may cross the line into unlawful tax evasion or tax fraud.
• Offshore Disclosures – Similar to income, offshore accounts and other foreign financial assets are subject to disclosure regardless of whether any tax is due. While minimum thresholds apply, most taxpayers with offshore accounts and other foreign financial assets must disclose these assets to the IRS and the Financial Crimes Enforcement Network (FinCEN) annually.
• Pandemic-Related Tax Fraud – Pandemic-related tax fraud remains a top enforcement priority for the IRS, IRS CI, and DOJ. This includes (but is not limited to) fraud under the Paycheck Protection Program (PPP) and Employee Retention Credit (ERC) program.

Along with these priority enforcement areas, the IRS and IRS CI are continuing to scrutinize taxpayers’ filings for evidence of other violations of the Internal Revenue Code. As a result, the following types of allegations can put individual and corporate taxpayers at risk for enforcement as well:

• Underreporting (or failing to report) non-payroll income
• Underreporting (or failing to report) international income
• Employers’ payroll taxes violations
• Fraudulent business deductions
• Cooperation between taxpayers and tax preparers when submitting fraudulent returns

Put our highly experienced team on your side

Dr. Nick Oberheiden

Founder

Attorney-at-Law

Lynette S. Byrd

Former DOJ Trial Attorney

Partner

Brian J. Kuester

Former U.S. Attorney

Hon. Kevin McCarthy

55th Speaker, U.S. House of Representatives (ret.)

Government Consultant

Mike Pompeo

Of Counsel

Former U.S. Secretary of State

John W. Sellers

Former Senior DOJ Trial Attorney

Linda Julin McNamara

Federal Appeals Attorney

Nicholas B. Johnson

Former Prosecutor

Roger Bach

Former Special Agent (DOJ)

Chris J. Quick

Former Special Agent (FBI & IRS-CI)

Michael S. Koslow

Former Supervisory Special Agent (DOD-OIG)

Ray Yuen

Former Supervisory Special Agent (FBI)

About Our Federal Tax Practice

The Orlando tax lawyers on our team have extensive experience representing individual and corporate taxpayers in high-stakes federal tax matters. If you need advice or representation regarding tax litigation or any of the following, we encourage you to contact us to arrange a complimentary initial consultation:

IRS Audits

Our attorneys represent individual and corporate taxpayers during correspondence audits, office audits, and field audits. While each type of audit presents unique challenges, all IRS audits can expose taxpayers to substantial liability for back taxes, interest, and penalties.

IRS Audit Appeals

We also represent individuals and organizations in IRS audit appeals. Taxpayers can challenge the outcomes of their appeals on various grounds, and filing a successful appeal can be a necessary step toward avoiding unwarranted liability. Filing an appeal may be necessary to prevent collection in some cases as well.

IRS CI Investigations

IRS CI investigates cases of suspected tax evasion, tax fraud, and other federal financial crimes. Due to the substantial risks involved in these investigations, any taxpayer that has received a target letter, search warrant, or subpoena should engage experienced defense counsel immediately.

Grand Jury Subpoenas

If IRS CI uncovers evidence of tax evasion, tax fraud, or other crimes, it will work with the DOJ to pursue federal charges. The first step in this process is the issuance of a grand jury subpoena. Once you have received a grand jury subpoena, time is of the essence, so it is critical to speak with an experienced Orlando tax attorney right away.

Criminal Prosecutions

Along with protecting our clients against facing federal criminal charges, we also defend individuals and companies that are facing criminal prosecution. If you or your company has been indicted for alleged criminal violations of the Internal Revenue Code, Bank Secrecy Act, or any other federal statute, our Orlando tax attorneys can get to work building a strategic defense immediately.

Voluntary Disclosures and Streamlined Filings

For taxpayers that have compliance-related concerns and are not yet facing scrutiny, submitting a voluntary disclosure or streamlined filing can be an essential step toward avoiding a high-stakes tax controversy. However, these can also be risky, and they are not options in all cases (when they are not, there are other options available). We can help you make informed and strategic decisions about how to deal with the IRS (or IRS CI) without triggering an audit or investigation.

Tax Relief and Resolution

We also help individuals and companies seek tax relief and amicably resolve tax disputes with the IRS. If you have questions about submitting an offer in compromise, negotiating a tax installment agreement, tax debt settlement, or payment plan, seeking penalty relief, or avoiding IRS collection, an experienced Orlando tax attorney at Oberheiden P.C. can walk you through your options and deal with the IRS on your (or your organization’s) behalf.

FAQs: Avoiding Unnecessary Federal Liability for Back Taxes, Interest, and Penalties

Schedule a Call with an Orlando Tax Attorney at Oberheiden P.C. Today

To schedule a free and confidential consultation with an Orlando tax lawyer at Oberheiden P.C., please call 888-680-1745 or contact us online. We will arrange for you to speak with one of our senior attorneys over the phone as soon as possible.

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