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Tax Attorney in Baltimore, MD

Federal IRS representation for Baltimore individuals and businesses — audits, back taxes, liens, levies, payroll-tax disputes, and U.S. Tax Court litigation right here at the Edward A. Garmatz United States Courthouse. We also coordinate Maryland Comptroller of Treasury matters under Form 2848 Power of Attorney where they sit alongside a federal case.

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Serving Baltimore City, Baltimore County, Anne Arundel, Howard, Harford, and the wider Chesapeake region

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If you owe back taxes in Baltimore, here is the 2026 picture

Maryland is one of the few states that stacks a county-level "piggyback" income tax on top of the graduated state personal income tax. The state rate runs from 2.0% to 5.75% under Md. Code, Tax-General § 10-105, and Baltimore City layers another 3.20% local income tax on top — the maximum local rate allowed in Maryland. The combined top marginal rate for a Baltimore City resident hits 8.95%, putting Baltimore among the highest state-plus-local income tax burdens in the country for middle-income earners. The corporate rate is 8.0% under Md. Code, Tax-General § 10-105(c). Baltimore is also one of only two cities in a state (with New Jersey) that imposes both a Maryland estate tax and a separate Maryland inheritance tax on the same death.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the Maryland Comptroller of Treasury has issued a Notice of Assessment with proposed tax, penalty, and interest, the deadline to act is short. We pull your IRS account transcripts, calculate your CSED, file Form 2848 Power of Attorney with the IRS and the Maryland Comptroller, and put administrative brakes on collection while the case is built.

Federal tax representation for Baltimore taxpayers

Victory Tax Lawyers, LLP is a California-Bar-admitted tax-resolution law firm based in Los Angeles. Our federal practice runs nationwide: the Internal Revenue Service accepts our Form 2848 Power of Attorney in every state, and the U.S. Tax Court — a single federal tribunal with jurisdiction over IRS deficiency cases — holds regular trial sessions in Baltimore at the Edward A. Garmatz United States Courthouse, 101 W Lombard Street. From our Robertson Boulevard office in Los Angeles, we represent Baltimore residents and Maryland-domiciled businesses in IRS audits, collection cases, Tax Court petitions, Offers in Compromise under IRC § 7122, Installment Agreements under IRC § 6159, lien discharges under IRC § 6325, levy releases under IRC § 6343, and Trust Fund Recovery Penalty defenses under IRC § 6672.

For Maryland state tax matters — the 2.0% to 5.75% graduated personal income tax under Md. Code, Tax-General § 10-105, the 3.20% Baltimore City piggyback local rate, the 8.0% Maryland corporate income tax, the 6.0% state sales tax under Md. Code, Tax-General § 11-101 (with a higher 9.0% rate on alcohol), withholding-tax assessments, or contested matters headed to the Maryland Tax Court — we file Form 2848 with the Comptroller and handle the administrative track directly. For formal litigation in the Maryland Tax Court (the state's specialized administrative tribunal, established in 1959 and one of the oldest dedicated state tax tribunals in the country) or in the Maryland Court of Special Appeals, we refer to locally admitted Maryland counsel under a co-counsel arrangement. The federal layer is where most Baltimore high-income, business-owner, and dual-residency cases live, and that is where our engagement carries the load.

Baltimore sits at an unusual intersection: Johns Hopkins University and Johns Hopkins Hospital (the largest private employer in Maryland) generate a steady stream of W-2 faculty income, 1099 attending-physician contracts, postdoctoral fellowships taxed under IRC § 117(c), and Hopkins Medical residency stipends with their own withholding quirks. T. Rowe Price (headquartered in Baltimore), the Franklin Templeton operations that absorbed Legg Mason, and Constellation Energy (which spun off from Exelon in 2022) drive heavy RSU, ISO, and IRC § 83(b) election activity. Under Armour, the Port of Baltimore's maritime workforce, NSA Fort Meade and U.S. Cyber Command in Anne Arundel County, the Aberdeen Proving Ground civilian and contractor base, and the casualty-and-business-interruption losses from the 2024 Francis Scott Key Bridge collapse under IRC § 165 and IRC § 1033 round out the city's tax-resolution footprint. The federal procedures are uniform; the facts are Baltimore-specific.

Your tax rights as a Baltimore taxpayer

Two parallel rights frameworks apply when you owe tax. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from the Tax-General Article of the Maryland Code and the Comptroller's Taxpayer Bill of Rights. Knowing both is the difference between a clean resolution and a missed 30-day Maryland Tax Court appeal window that ends in a state tax lien against your Federal Hill, Canton, or Mount Vernon property.

Right to representation

IRC § 7521(b)(2) and (c) give you the right to be represented by an attorney, CPA, or Enrolled Agent during any IRS examination or interview. Once Form 2848 is on file, the IRS must deal with us first, not you. Maryland mirrors this through Comptroller Form 548 Power of Attorney, accepted for all Comptroller of Treasury matters.

Right to U.S. Tax Court review

IRC § 6213(a) gives you 90 days from a Statutory Notice of Deficiency to petition the U.S. Tax Court without paying the tax first. Miss the 90 days and the federal assessment becomes final. The U.S. Tax Court holds regular trial sessions in Baltimore at the Edward A. Garmatz United States Courthouse, 101 W Lombard Street.

Right to Maryland Tax Court review

Md. Code, Tax-General § 13-510 gives you 30 days from a final Comptroller Notice of Assessment to appeal to the Maryland Tax Court — the state's specialized administrative tribunal seated at 6 Saint Paul Street in Baltimore. The 30-day window is much tighter than the federal 90-day Tax Court deadline. Missing it forfeits the right to pre-payment review.

Collection Due Process

IRC § 6320 (lien) and IRC § 6330 (levy) give you a 30-day window to request a CDP hearing once the IRS files a Notice of Federal Tax Lien or issues a Final Notice of Intent to Levy. A timely CDP filing halts collection and preserves judicial review.

Right to settle for less than owed

Federally, IRC § 7122 authorizes Offers in Compromise based on doubt as to liability, doubt as to collectibility, or effective tax administration. Maryland runs a parallel program under Md. Code, Tax-General § 13-1101 and Comptroller Form MD 656, with similar hardship and insolvency standards. Both programs require all returns filed before consideration.

Right to recover fees

IRC § 7430 allows recovery of administrative and litigation costs if the IRS takes a position that is not substantially justified and the taxpayer prevails. The threshold is high, but real, especially in audit reconsideration and Innocent Spouse cases under IRC § 6015.

How Victory Tax Lawyers helps Baltimore taxpayers

Offer in Compromise under IRC § 7122

We file Form 656 with Form 433-A(OIC) or 433-B(OIC), document the Reasonable Collection Potential, and negotiate doubt-as-to-collectibility offers when full collection is not feasible within the remaining CSED. For Baltimore taxpayers, a federal OIC does not resolve Maryland state liability; we run a parallel Maryland Form MD 656 filing with the Comptroller of Treasury under Md. Code, Tax-General § 13-1101 where the state debt is real.

Installment Agreements under IRC § 6159

Streamlined IAs (under $50,000), partial-pay IAs under IRC § 6159(d), and full-pay agreements. We push for partial-pay structures where the IRC § 6502 ten-year CSED will extinguish the balance before payoff — the most under-used resolution path for Baltimore taxpayers carrying between $50,000 and $250,000 in federal debt, particularly Johns Hopkins faculty with deferred-compensation deferrals that have caught up with them.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Baltimore property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Baltimore City Circuit Court Clerk encumber title on Federal Hill, Canton, Fells Point, Mount Vernon, and Locust Point row houses; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing.

Levy release under IRC § 6343

Wage levies, bank levies, and accounts-receivable levies. We document economic hardship under IRC § 6343(a)(1)(D) and Treasury Reg. § 301.6343-1(b)(4), and where the levy is procedurally defective, we challenge it through Collection Due Process or Appeals. Maryland state tax liens follow a parallel track under Md. Code, Tax-General § 13-805 and § 13-806, recorded with the Circuit Court Clerk in the county of the taxpayer's property.

Audit defense and U.S. Tax Court litigation

Correspondence audits, office audits, and field examinations — including sensitive issues like cryptocurrency, foreign accounts under FinCEN Form 114 (FBAR), S-corporation reasonable-compensation, Hopkins postdoctoral fellowship characterization under IRC § 117(c), and Francis Scott Key Bridge business-interruption casualty claims under IRC § 165 and IRC § 1033 involuntary conversion treatment. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Baltimore trial sessions are held at the Garmatz Courthouse.

Penalty abatement under IRC § 6651 and IRM 20.1.1

First-Time Abate administrative relief, reasonable-cause abatement, and statutory exceptions for failure-to-file and failure-to-pay penalties. On accuracy-related penalties under IRC § 6662, we document substantial authority or adequate disclosure to defeat the assessment. Maryland penalties under Md. Code, Tax-General § 13-701 and § 13-702 follow a separate reasonable-cause analysis applied by the Comptroller and reviewable by the Maryland Tax Court.

Twelve types of Baltimore tax matters we handle

Federal cases for Baltimore residents and businesses, framed against the Maryland Comptroller overlay where it matters.

Johns Hopkins faculty, postdoc, and physician income

Hopkins faculty hold a mix of W-2 academic salary, 1099 attending-physician fees from Johns Hopkins Hospital, and IRC § 117(c) taxable postdoctoral fellowship amounts that are routinely under-withheld. Medical residents with Pell-Grant-style stipends often misclassify the taxable portion. Add the Baltimore City 3.20% piggyback rate and the combined federal-plus-state-plus-local burden makes withholding accuracy an absolute requirement.

RSU and ISO underwithholding

T. Rowe Price, Franklin Templeton (Legg Mason successor), Constellation Energy, and Under Armour all issue equity compensation. RSU vest events generate W-2 inclusion taxed at default 22% supplemental rate — well below the actual marginal rate for high earners. ISO disqualifying dispositions trigger AMT under IRC § 55. IRC § 83(b) elections for restricted-stock grants demand exact 30-day filing windows.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Baltimore restaurant, hospitality, port-services, and construction owners are the most common targets. The IRS uses Form 4180 interviews to identify responsible persons; Maryland applies a parallel responsible-person rule to withheld state income tax under Md. Code, Tax-General § 13-1101.

Maryland estate and inheritance tax

Maryland is one of only two states (with New Jersey) that imposes both a state estate tax and a separate state inheritance tax on the same death. The Maryland estate tax exemption is $5 million per estate under Md. Code, Tax-General § 7-309; the inheritance tax under Md. Code, Tax-General § 7-204 hits non-lineal beneficiaries at 10%. Coordinating the federal estate tax (Form 706, $13.61M exemption for 2024) with both Maryland layers is its own engagement on top of a federal income-tax matter.

Notice of Federal Tax Lien

NFTLs filed with the Circuit Court for Baltimore City Clerk encumber title and trigger CDP rights under IRC § 6320. A parallel Maryland state tax lien may be recorded under Md. Code, Tax-General § 13-805. Federal Hill, Canton, Fells Point, Mount Vernon, and Locust Point row-house refinances and sales stall fast when an NFTL hits the title search.

IRS bank or wage levy

Bank levies on accounts held at M&T Bank (headquartered in Buffalo but the dominant Baltimore retail bank after acquiring Mercantile), Truist, PNC, Wells Fargo, Bank of America, or any Maryland-chartered bank. Wage levies hit Baltimore employers within days of CP90 or LT11 issuance.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. With BWI Thurgood Marshall Airport and the Port of Baltimore as major international gateways, this hits frequent business travelers, Hopkins international researchers, and maritime crews especially hard. We file the IRC § 7345(e) action to reverse the certification.

FBAR and FATCA non-disclosure

FinCEN Form 114 for foreign accounts over $10,000 aggregate. Baltimore's Greek (Greektown / Highlandtown), Korean (Park Heights and Catonsville), Jewish (Pikesville and Owings Mills), West African, and Caribbean communities all carry steady FBAR exposure on overseas accounts inherited from family or maintained for cross-border business. The IRS Streamlined Filing Compliance Procedures are a frequent engagement.

Real-estate flipping and short-term rentals

Federal Hill, Canton, Fells Point, Mount Vernon, Locust Point, and Hampden saw a row-house investor wave after 2020. IRC § 1031 like-kind exchanges done without a qualified intermediary, dealer-status reclassification under IRC § 1221, and STR misclassification under IRC § 280A and the seven-day rule all produce assessments. Baltimore City and Baltimore County issue separate short-term-rental licensing that the IRS may review on audit.

Innocent Spouse Relief

IRC § 6015 relief for spouses jointly liable on a return where the other spouse's items caused the deficiency. We file Form 8857 with a clean factual record — especially common in divorces involving Hopkins physicians with side practices and small-business owners across the port economy.

Federal employee and contractor tax issues

NSA Fort Meade, U.S. Cyber Command, the Aberdeen Proving Ground, Coast Guard Yard Curtis Bay, and the cluster of federal contractors around the Baltimore-Washington corridor produce a steady book of W-2 federal employee cases, security-clearance debt sensitivity, and 1099 contractor underpayment under IRC § 6654. Clearance holders are particularly exposed to passport and travel impacts of a federal tax lien.

Cryptocurrency tax assessments

CP2000 notices on unreported digital-asset gains, basis-tracking failures, and DeFi-protocol income. Baltimore's biotech and Hopkins-adjacent tech population picked up substantial crypto exposure through 2021-2024. Form 1099-DA reporting (effective 2025) drives the matching cases.

Nine common causes of tax debt for Baltimore taxpayers

Patterns we see repeatedly in Baltimore-based engagements. None of them are unusual — all of them are resolvable.

1. Underwithheld RSU vest events

A T. Rowe Price, Constellation Energy, or Under Armour employee at the 35% or 37% federal marginal bracket sees only 22% supplemental withholding on RSU vests. The shortfall, plus 5.75% Maryland plus 3.20% Baltimore City local, produces a five-figure balance due the following April.

2. Self-employment underpayment

Hopkins attending physicians with private 1099 practices, consultants in the federal contracting corridor, real-estate agents, and tradespeople file Schedule C or K-1 income with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654.

3. Business closure

When an LLC or S-corp closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Common after the 2024 bridge-collapse business disruption rippled through the port economy.

4. Divorce and joint-return fallout

A jointly-filed return tied to a now-former spouse's understatement leaves both parties liable until Innocent Spouse relief under IRC § 6015 is granted.

5. Identity theft and fraudulent returns

A return filed in your name with refund redirected. Form 14039 opens the IRS identity-theft case; the assessment must be corrected, not just protested.

6. Cryptocurrency CP2000 surprise

Exchanges issue Form 1099-DA (introduced 2025), and the IRS computer matches reported gains. Missed basis records turn into ordinary-income assessments at the full sale price.

7. Late-filed or unfiled returns

Failure-to-file under IRC § 6651(a)(1) compounds at 5% per month, capped at 25%. After three years, refunds are barred under IRC § 6511. Maryland mirrors the federal three-year refund bar under Md. Code, Tax-General § 13-1104.

8. Real-estate sale without estimated tax

A Federal Hill, Canton, Locust Point, or Mount Vernon row-house sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Investor flips taxed at ordinary-income rates — not capital-gain — under the dealer-status rules of IRC § 1221.

9. Stock-option exercise without planning

ISO disqualifying dispositions and NSO ordinary-income inclusions hit Baltimore biotech, financial-services, and Constellation Energy employees with AMT under IRC § 55 and large balances due. IRC § 83(b) elections missed within the 30-day window create their own irreversible problem.

Eight tax liabilities that pull in Baltimore taxpayers

Federal authority alongside the Maryland statute where there is a parallel.

Failure to file federal return

IRC § 6651(a)(1) imposes 5%/month, max 25%, plus interest under IRC § 6601. The Maryland mirror is Md. Code, Tax-General § 13-701 imposing a similar late-filing penalty on unpaid Maryland tax.

Failure to file Maryland state return

Md. Code, Tax-General § 13-701 imposes a 10% penalty on the unpaid tax for failure to file, plus interest under § 13-604. The Comptroller may issue a Notice of Assessment under § 13-401 triggering the 30-day Maryland Tax Court appeal window. The Baltimore City local piggyback rate of 3.20% is collected by the Comptroller and distributed to the city.

Federal § 7122 Offer in Compromise eligibility

All federal returns must be filed (IRC § 7122(d) compliance) and the offer must reflect Reasonable Collection Potential. The non-refundable $205 application fee may be waived for low-income certified offers.

Maryland sales-tax delinquency

Md. Code, Tax-General § 11-101 sets the 6.0% state sales tax (Maryland has no local-option sales tax stack, simplifying the rate but raising the base). The 9.0% rate on alcohol is administered separately. Md. Code § 13-1101 imposes personal liability on responsible persons for unpaid trust-fund sales tax.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Maryland applies a parallel responsible-person rule to withheld state income tax under Md. Code, Tax-General § 13-1101.

Accuracy-related penalty

IRC § 6662 imposes 20% on substantial-understatement or negligence; IRC § 6663 imposes 75% on fraud. Defense is built on substantial authority, adequate disclosure, or reasonable cause.

Maryland estate and inheritance tax

Md. Code, Tax-General § 7-309 imposes the Maryland estate tax (16% top rate on amounts over $5 million). Md. Code, Tax-General § 7-204 imposes a separate Maryland inheritance tax at 10% on transfers to non-lineal beneficiaries (siblings, nieces/nephews, friends; lineal descendants and spouses are exempt). The two layers can apply to the same decedent's estate, with separate filings on Form MET-1 and Form MET-2.

Transferee liability

IRC § 6901 lets the IRS pursue a transferee — a person who received property from a delinquent taxpayer — for the transferor's unpaid tax, up to the value of the transferred property.

What resolution can look like

Debt reduced

An accepted IRC § 7122 Offer in Compromise can resolve six-figure balances for cents on the dollar where Reasonable Collection Potential supports the offer. The acceptance rate sits around 33% nationally; preparation determines the outcome.

Penalties abated

First-Time Abate removes a single year of failure-to-file or failure-to-pay penalties for taxpayers with a clean three-year compliance record. Reasonable-cause abatement under IRM 20.1.1 reaches further when supported by documentation.

Lien released or withdrawn

Once a debt is paid in full, the IRS releases the Notice of Federal Tax Lien within 30 days per IRC § 6325(a). On an Installment Agreement of $25,000 or less, lien withdrawal under Form 12277 can be requested to clear title with the Circuit Court for Baltimore City Clerk.

Sample tax-resolution outcomes

Anonymized client matters drawn from our $100M+ aggregate tax-relief record across 2,000+ resolved cases.

Year Tax debt Resolution Final outcome
2024 $152,296 IRC § 6159 Installment Agreement Accepted at $25/month, partial-pay
2024 $138,296 Streamlined Installment Agreement Accepted at $25/month
2023 $130,555 Partial-Pay Installment Agreement Accepted at $50/month
2023 $128,206 IRC § 6159 Installment Agreement Accepted at $25/month
2022 $116,451 Partial-Pay Installment Agreement Accepted at $50/month

Past results do not guarantee future outcomes. Each tax case is unique. Results depend on the specific facts of the matter, including the taxpayer's financial condition, compliance history, and the discretion of the Internal Revenue Service and the Maryland Comptroller of Treasury.

Why Victory Tax Lawyers for a Baltimore federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Maryland-Bar-admitted. That distinction matters — and it does not block our work. The U.S. Tax Court is a federal court with nationwide jurisdiction; an attorney admitted to that court may petition and try cases at any of its trial locations, including Baltimore at the Edward A. Garmatz United States Courthouse. IRS administrative practice runs on Form 2848 Power of Attorney, which is accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Baltimore clients never need a separately admitted Maryland attorney because the case is, at its core, federal.

For administrative work before the Maryland Comptroller of Treasury — protests, audit responses, OIC submissions under Md. Code, Tax-General § 13-1101, and installment-agreement requests — we file Comptroller Form 548 Power of Attorney and handle the matter remotely. When a case must move to the Maryland Tax Court (the state's specialized administrative tribunal, established 1959, seated at 6 Saint Paul Street in Baltimore) or appeal further to the Maryland Court of Special Appeals, we coordinate with locally admitted Maryland counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the bigger exposure given Maryland's high combined state-plus-local income-tax burden, stays with us.

What distinguishes our firm: a California-Bar-admitted managing attorney with active U.S. Tax Court admission, an Enrolled Agent on staff for IRS administrative work, a 5.0 / 72-review Google rating, and $100M+ in cumulative tax relief secured across 2,000+ resolved matters. No marketing claim of being a Maryland-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Baltimore taxpayer, at the same standard we apply to a Los Angeles client. Our 100% remote workflow runs through a secure document portal — you never have to drive to Robertson Boulevard.

Our seven-step process for Baltimore clients

1

Free consultation

A 30-minute call with a tax attorney to scope your matter, identify deadlines, and decide whether engagement is the right move.

2

Engagement letter

A written scope, fee structure, and conflict check. Flat fees for administrative resolution; hourly or hybrid for litigation.

3

Form 2848 and CAF

We file the federal Power of Attorney with the IRS and Form 548 with the Maryland Comptroller, register on the CAF system, and step in as the contact of record.

4

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events.

5

Strategy memo

A written summary: the resolution path (OIC, IA, CNC, audit response, CDP, Tax Court), the timeline, and the realistic outcome range.

6

Filing and negotiation

We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, or a Maryland Tax Court petition through local counsel — and handle every IRS and Comptroller contact.

7

Compliance monitoring

After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, and prevent default.

Two collection clocks: federal CSED and Maryland's seven-year statute

The IRS has ten years from the date of assessment to collect a federal tax under IRC § 6502. After the Collection Statute Expiration Date, the debt is extinguished by operation of law. The clock pauses (“tolls”) when an Offer in Compromise is pending, when a Collection Due Process petition is filed, during bankruptcy, when an installment agreement is requested, and when the taxpayer is outside the United States for six months or more.

Maryland runs a parallel state collection rule under Md. Code, Tax-General § 13-1103: the Comptroller must assess Maryland income tax within three years of the return due date (Md. Code, Tax-General § 13-1101 extends the period to seven years for substantial understatement or unreported gross income exceeding 25%, with no statute on collection in cases of fraud or non-filing). Once assessed, the Comptroller's collection right runs for seven years from the date of assessment under Md. Code, Tax-General § 13-1103, with renewal possible by re-recording the state tax lien. Many Baltimore taxpayers carry a federal CSED that will run out before the Maryland collection statute expires — or vice versa. Pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.

Baltimore tax authorities and venues

A working knowledge of the tribunals, agencies, and field offices in Baltimore is what separates an answered Notice from a wage levy. Below is the working list our firm uses on every Baltimore matter.

Internal Revenue Service — Baltimore TAC

The federal tax authority, at irs.gov. The Baltimore Taxpayer Assistance Center operates at 31 Hopkins Plaza in the George H. Fallon Federal Building, Baltimore MD 21201. Appointments required.

U.S. Tax Court — Baltimore trial sessions

The U.S. Tax Court holds regular trial sessions in Baltimore at the Edward A. Garmatz United States Courthouse, 101 W Lombard Street, Baltimore MD 21201. Petitions are filed at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

Maryland Comptroller of Treasury

The state tax authority, at marylandtaxes.gov. Headquartered at 80 Calvert Street, Annapolis MD 21401, with the Baltimore office at 301 W Preston Street, Baltimore MD 21201. Administers the 2.0-5.75% graduated personal income tax, the 8.0% corporate income tax, the 6.0% state sales tax (9.0% on alcohol), withholding tax, the Baltimore City and Baltimore County piggyback local rates (collected by the Comptroller), the Maryland estate tax under Md. Code, Tax-General § 7-309, the Maryland inheritance tax under § 7-204, and the Maryland Offer in Compromise program under Form MD 656.

Maryland Tax Court

The state's specialized administrative tax tribunal, established 1959 and one of the oldest dedicated state tax tribunals in the country. Seated at 6 Saint Paul Street, Baltimore MD 21202. Hears disputes between taxpayers and the Maryland Comptroller of Treasury, the State Department of Assessments and Taxation, and other tax-administering agencies. 30-day appeal deadline from a final Comptroller assessment under Md. Code, Tax-General § 13-510. Decisions are appealable to the Maryland Court of Special Appeals.

City of Baltimore Department of Finance

The municipal finance authority for Baltimore City (which is an independent city under the Maryland Constitution, not part of any county). Office at 200 Holliday Street, Baltimore MD 21202. Page: finance.baltimorecity.gov. The Director of Revenue Collections at the same address administers Baltimore City property tax and supports collection of the Baltimore City 3.20% local income-tax piggyback (collected by the Maryland Comptroller and distributed back to the city). NFTLs affecting Baltimore City property are recorded with the Circuit Court for Baltimore City Clerk.

Baltimore County Office of Budget and Finance

The county finance authority for Baltimore County, which is a separate jurisdiction from Baltimore City. Office at 400 Washington Avenue, Towson MD 21204. Administers Baltimore County property-tax billing and supports the Baltimore County 3.20% piggyback local income-tax rate. NFTLs affecting county property (Towson, Catonsville, Pikesville, Owings Mills, Dundalk) are recorded with the Circuit Court for Baltimore County Clerk in Towson.

U.S. District Court — District of Maryland, Baltimore Division

Refund suits filed after payment of tax and exhaustion of administrative remedies under IRC § 7422 may be brought in the U.S. District Court (D. Md., Baltimore Division), located at the Garmatz Courthouse, 101 W Lombard Street, or the U.S. Court of Federal Claims in Washington, D.C.

IRS Independent Office of Appeals

The administrative-appeals body within the IRS that resolves cases without litigation. Baltimore cases run through the Appeals offices serving the Mid-Atlantic region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Taxpayer Advocate Service — Baltimore

An independent organization within the IRS that helps when normal channels stall. The Baltimore Local Taxpayer Advocate office serves taxpayers across Maryland. Page: taxpayeradvocate.irs.gov.

State Department of Assessments and Taxation (SDAT)

Maryland's separate property-tax assessment agency, at 700 E. Pratt Street, Baltimore MD 21202. Page: dat.maryland.gov. Administers real-property assessments for both Baltimore City and Baltimore County, business personal-property reporting, and the Homestead Tax Credit. Property-tax assessment appeals run to the Property Tax Assessment Appeal Boards and then to the Maryland Tax Court.

Speak with a tax attorney about your Baltimore matter

Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, or a Maryland Comptroller Notice of Assessment is in front of you, the deadline to respond is real and short — call today.

Call (800) 883-8301 Free Consultation

Frequently asked questions — Baltimore tax

Why is the Baltimore combined income-tax rate so high?

Maryland is one of a small number of states that allows local jurisdictions to layer a "piggyback" income tax on top of the state graduated rate. The state personal income tax runs from 2.0% to 5.75% under Md. Code, Tax-General § 10-105. Baltimore City imposes the maximum-allowed local rate at 3.20% (Baltimore County is also at 3.20%, Howard County at 3.20%, Anne Arundel at 2.81%, Harford at 3.06%). For a Baltimore City resident at the top state bracket, the combined state-plus-local rate hits 8.95% — one of the highest middle-and-upper-income marginal rates in the country, sitting closer to California's combined burden than to a neighboring state like Virginia (top rate 5.75% with no local layer). The Comptroller of Treasury collects the local piggyback alongside the state portion and distributes it back to the local jurisdiction.

Where is the closest U.S. Tax Court trial location to Baltimore?

The U.S. Tax Court holds regular trial sessions in Baltimore itself at the Edward A. Garmatz United States Courthouse, 101 W Lombard Street. A taxpayer anywhere in Maryland can request the Baltimore trial location when filing the Tax Court petition. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline from the IRS Statutory Notice of Deficiency under IRC § 6213(a) is jurisdictional — a single day late and the federal assessment becomes final.

What is the Maryland Tax Court and what is its deadline?

The Maryland Tax Court is the state's specialized administrative tax tribunal, established in 1959 and among the oldest dedicated state tax tribunals in the country. It sits at 6 Saint Paul Street, Baltimore MD 21202, and hears disputes between taxpayers and the Maryland Comptroller of Treasury, the State Department of Assessments and Taxation, and other tax-administering agencies. The appeal deadline is 30 days from a final Comptroller assessment under Md. Code, Tax-General § 13-510 — significantly tighter than the federal 90-day Tax Court deadline. Decisions are appealable to the Maryland Court of Special Appeals. Victory Tax Lawyers refers Maryland Tax Court litigation to locally admitted Maryland counsel; we handle the federal portion and the Comptroller administrative work directly.

Is Baltimore City actually part of Baltimore County?

No. Baltimore City has been a separate independent jurisdiction since 1851 under the Maryland Constitution — Maryland's only independent city, and one of a small number of independent cities in the United States. Baltimore City is governed separately from Baltimore County and has its own Mayor and City Council, its own Circuit Court, its own Department of Finance at 200 Holliday Street, and its own property-tax rate. Baltimore County is a surrounding jurisdiction with its seat in Towson at 400 Washington Avenue. The two share a name and an economic region but are administratively distinct — an important distinction when an NFTL is recorded, since the lien must be filed with the correct Circuit Court Clerk to encumber a given property.

What is Maryland's collection statute of limitations?

Md. Code, Tax-General § 13-1101 gives the Comptroller three years from a return's due date to assess Maryland income tax (seven years for substantial understatement of gross income exceeding 25%, with no limit for fraud or unfiled returns). Once an assessment is final, the Comptroller's right to collect runs for seven years under Md. Code, Tax-General § 13-1103, renewable by re-recording the state tax lien. The federal CSED under IRC § 6502 is a separate ten-year clock running from the federal assessment date.

Can I be audited by both the IRS and the Maryland Comptroller for the same year?

Yes. The IRS and the Maryland Comptroller of Treasury operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to Maryland under the state's federal-change reporting rule (Md. Code, Tax-General § 13-409), and vice versa. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the Maryland return — particularly important given the 3.20% Baltimore City piggyback, which multiplies any federal adjustment by an additional layer of state-plus-local tax.

Does Maryland offer an Offer in Compromise equivalent to the federal program?

Yes. The Maryland Comptroller of Treasury accepts Offers in Compromise on Form MD 656 under Md. Code, Tax-General § 13-1101 authority. The Comptroller considers offers based on doubt as to collectibility, doubt as to liability, and economic hardship — standards that parallel federal IRC § 7122 analysis but with state-specific procedural rules. All Maryland returns must be filed before consideration, and a financial-disclosure package is required. We typically run a state OIC in parallel with the federal Offer where both debts are real.

I'm a Johns Hopkins postdoctoral fellow — is my stipend taxable?

Usually yes, in part. IRC § 117(a) excludes amounts paid as a "qualified scholarship" used for tuition and required fees of a degree candidate; IRC § 117(c) makes everything else taxable, including any portion of a fellowship paid for services (teaching, research, lab work) and any portion paid for room, board, or general support. Most postdoctoral fellowships at Hopkins (NIH F32, NRSA-supported positions, internal Hopkins fellowships) are not for degree candidates and are partly or fully taxable. The institution often does not withhold, so quarterly estimated payments under IRC § 6654 are required. Maryland follows the federal definition under Md. Code, Tax-General § 10-208 for additions and subtractions. The Baltimore City 3.20% local rate applies on top.

Can a California-Bar-admitted attorney represent me in Baltimore?

For federal IRS matters — yes. The IRS accepts Form 2848 Power of Attorney from any attorney in good standing with any state bar. The U.S. Tax Court is a single federal court with nationwide jurisdiction; an attorney admitted to that court may represent a taxpayer at any Tax Court trial location, including Baltimore. For Maryland Comptroller administrative work, we file Form 548 Power of Attorney and handle the matter remotely. For formal litigation in the Maryland Tax Court or a Maryland Court of Special Appeals proceeding, we co-counsel with locally admitted Maryland attorneys. Most engagements — audit defense, OIC, IA, levy release, Tax Court — are federal and stay entirely with our firm.

What if I have unfiled returns going back several years?

The IRS Voluntary Filing Compliance policy and IRM 5.1.11.6 generally require the last six years of returns to bring a taxpayer back into compliance. Filing prior-year returns is the first step before any OIC, IA, or CNC request — IRC § 7122(d) compliance is a prerequisite for a federal Offer. Refunds claimed on returns filed more than three years after the original due date are time-barred under IRC § 6511(b)(2). Maryland follows a parallel filing-compliance posture; the Comptroller may assess based on the federal-change reporting rule or estimate tax under Md. Code, Tax-General § 13-401 when a taxpayer fails to file.

Can the IRS levy my Baltimore bank account or wages?

Yes — after a Final Notice of Intent to Levy (CP90 or LT11) and expiration of the 30-day Collection Due Process window under IRC § 6330, the IRS may levy bank accounts at M&T Bank, Truist, PNC, Wells Fargo, Bank of America, or any Maryland-chartered institution and serve wage levies on Baltimore employers including Johns Hopkins, T. Rowe Price, Constellation Energy, and Under Armour. A timely Form 12153 CDP request halts collection while the case is reviewed by Appeals. After a CDP determination, the taxpayer has 30 days to petition the U.S. Tax Court under IRC § 6330(d)(1). Maryland issues parallel state tax liens under Md. Code, Tax-General § 13-805 that work through Circuit Court Clerk filings.

I work for T. Rowe Price / Constellation / Under Armour and have RSUs — why did I owe so much tax this year?

RSU vest events are taxed as W-2 ordinary income at the supplemental wage withholding rate, which is currently 22% federal on amounts up to $1 million per year (37% above). If your actual marginal federal rate is 32%, 35%, or 37%, you are underwithheld by 10 to 15 percentage points on every vest. Add 5.75% Maryland state plus the 3.20% Baltimore City local piggyback (with limited state withholding on supplemental wages depending on the employer's setup) and a single year of vesting can produce a $30,000 to $100,000+ balance due. The fix is W-4 adjustment plus quarterly Form 1040-ES under IRC § 6654.

My family member died in Maryland — do I owe both estate and inheritance tax?

Potentially yes. Maryland is one of only two states (New Jersey is the other) that imposes both a state estate tax and a separate state inheritance tax on the same death. The Maryland estate tax under Md. Code, Tax-General § 7-309 applies to gross estates above $5 million per decedent, with a top rate of 16%, and is filed on Form MET-1. The Maryland inheritance tax under Md. Code, Tax-General § 7-204 is imposed on the beneficiary, not the estate, at a 10% rate on transfers to non-lineal beneficiaries (siblings, nieces, nephews, friends, business partners); transfers to spouses, parents, children, grandchildren, and other direct lineal descendants are exempt. The two layers can stack on the same estate. The federal estate tax under Form 706 ($13.61M exemption for 2024) is a third layer on top.

My business was hurt by the Francis Scott Key Bridge collapse in 2024 — are there tax options?

Yes. Businesses with documented economic losses tied to the March 2024 bridge collapse may qualify for IRC § 165 casualty-and-business-loss deductions, and where property was destroyed or rendered unusable, IRC § 1033 involuntary-conversion rules permit deferral of gain when replacement property is acquired within the statutory window (generally two years, extended to four years for federally declared disaster areas). The IRS issued specific disaster-relief filing-and-payment extensions for affected Maryland taxpayers following the collapse; some of those extensions have run, but related casualty claims and audit defenses on already-claimed losses remain active. We have handled IRC § 1033 and casualty-loss matters for port-area businesses and recommend a transcript review before claiming or amending.

How long does a federal Offer in Compromise take to process?

An IRS Offer in Compromise typically takes six to twelve months from filing to a final decision. The IRS deems an Offer accepted if not rejected within 24 months under IRC § 7122(f). While the OIC is pending, IRC § 6331(k) bars most levies, and the CSED is tolled. Rejected offers carry a 30-day Appeals window. A well-documented Offer with a complete Form 433-A(OIC) or 433-B(OIC) financial package moves faster than one returned for incompleteness. A Maryland state OIC under Form MD 656 typically runs four to nine months on a parallel track.

Will hiring a tax attorney stop IRS collection action immediately?

Once Form 2848 is on file, the IRS routes all communication through the attorney and stops contacting the taxpayer directly. Active levies are not automatically lifted by the POA filing alone — release requires either a financial showing under IRC § 6343, a CDP filing under IRC § 6330, or an installment-agreement / OIC submission that triggers the IRC § 6331(k) collection bar. We move on those concurrently when a levy is in place. Maryland state collection follows a similar pattern: a Form 548 routes Comptroller contact, and a pending Maryland OIC pauses state tax-lien enforcement.

About the author

This page was written and reviewed by Parham Khorsandi, Esq., Managing Attorney of Victory Tax Lawyers, LLP. Cal Bar #266658. Admitted to practice before the United States Tax Court. Mr. Khorsandi has resolved over 2,000 federal tax matters and secured more than $100 million in tax relief for clients across all 50 states.

Page last reviewed: . Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Maryland statute citation references the Annotated Code of Maryland, Tax-General Article. Every administrative authority links to its primary .gov source. Material changes to the law are reflected within 30 days of effective date.

Attorney Advertising. This page is provided by Victory Tax Lawyers, LLP for general informational purposes only. Nothing on this page constitutes legal advice, creates an attorney-client relationship, or substitutes for consultation with a licensed attorney about your specific tax matter. Prior results described or referenced do not guarantee a similar outcome. Each tax case turns on its individual facts, applicable law, and the discretion of the Internal Revenue Service, the Maryland Comptroller of Treasury, the U.S. Tax Court, the Maryland Tax Court, or other adjudicating body.

Victory Tax Lawyers, LLP is California-Bar-admitted with its principal office at 1100 S. Robertson Blvd., Los Angeles, CA 90035. The firm represents clients in federal tax matters nationwide via Form 2848 Power of Attorney and admission to the United States Tax Court. The firm is not admitted to practice in the courts of the State of Maryland; where a Maryland state-court appearance or Maryland Tax Court litigation is required, the firm associates with locally admitted counsel.

IRS Circular 230 Disclosure: The discussion of U.S. federal tax issues on this page is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties imposed under the Internal Revenue Code or for promoting, marketing, or recommending to another party any tax-related matters addressed. For specific tax advice, consult independent tax counsel.

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