Tax Attorney in Bellevue, NE

Federal IRS representation for Bellevue Nebraska individuals, Offutt Air Force Base military families, U.S. Strategic Command staff, 55th Wing reconnaissance personnel, cleared defense contractors, and Sarpy County small-business owners — audits, back taxes, liens, levies, payroll-tax disputes, and U.S. Tax Court litigation at the Roman L. Hruska Federal Courthouse in Omaha, twelve miles north. We also coordinate Nebraska Department of Revenue and Sarpy County inheritance-tax matters under IRS Form 2848 federal Power of Attorney and Nebraska Form 33 state Power of Attorney where they sit alongside a federal case.

Reviewed by Parham Khorsandi, Esq. — California Bar #266658. Last reviewed: May 25, 2026.

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Serving Offutt AFB, Old Towne Bellevue, Twin Creek, Galvin Heights, Olde Towne, Avery, Fontenelle Forest, Cornhusker Road, Bellevue West, Bellevue East, Papillion, La Vista, Gretna, Springfield, and the wider Sarpy County footprint

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

Nebraska runs a graduated personal income tax from 2.46% to 5.84% under Neb. Rev. Stat. § 77-2715.01, with the top rate scheduled to phase down to 3.99% by 2027 under LB873. The state Corporate Income Tax at 5.84% under Neb. Rev. Stat. § 77-2734.02 is also phasing down on a parallel schedule. Bellevue layers a 1.5% local sales-tax stack on top of the 5.5% state rate under Neb. Rev. Stat. § 77-2701, bringing the combined Bellevue sales tax to 7% on most transactions. Unlike most states, Nebraska imposes no state estate tax but does impose a county-administered Nebraska Inheritance Tax under Neb. Rev. Stat. § 77-2001, with rates ranging from 1% to 18% depending on the heir's relationship to the decedent — a unique structure assessed and collected by the Sarpy County Treasurer for Bellevue-domiciled estates. Add the federal layer and the combined Bellevue federal-state-county exposure on a high-bracket Offutt-orbit defense contractor or a senior 55th Wing officer runs well above what the headline 5.84% Nebraska top bracket suggests.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, a Nebraska Department of Revenue Notice of Deficiency or Notice of Assessment, or a Sarpy County inheritance-tax billing, 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 Nebraska Form 33 with the Nebraska DOR, and put administrative brakes on collection while the case is built.

Federal tax representation for Bellevue Nebraska 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 twelve miles north of Bellevue in Omaha, at the Roman L. Hruska Federal Courthouse, 111 South 18th Plaza. From our Robertson Boulevard office in Los Angeles, we represent Bellevue Nebraska residents, Offutt Air Force Base military families, U.S. Strategic Command (USSTRATCOM) staff, 55th Wing reconnaissance personnel, cleared defense contractors, and Sarpy County small-business owners 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. The IRS Taxpayer Assistance Center closest to Bellevue sits twelve miles north in downtown Omaha at 1616 Capitol Avenue, Suite 200, three blocks from the federal courthouse.

For Nebraska state-tax matters — the graduated 2.46% to 5.84% personal income tax under Neb. Rev. Stat. § 77-2715.01, the 5.84% Corporate Income Tax under Neb. Rev. Stat. § 77-2734.02, the 5.5% state sales tax under Neb. Rev. Stat. § 77-2701, withholding-tax assessments, and contested matters headed to the Nebraska Tax Equalization and Review Commission — we file Nebraska Form 33 with the Department of Revenue and handle the administrative track directly. The Nebraska DOR is headquartered at 301 Centennial Mall South, 5th Floor, Lincoln NE 68509. For formal litigation before the Nebraska Tax Equalization and Review Commission (TERC), an independent administrative tribunal at 301 Centennial Mall South, 4th Floor, in Lincoln, or further appeal to the Nebraska Court of Appeals or the Nebraska Supreme Court, we refer to locally admitted Nebraska counsel under a co-counsel arrangement. The federal layer is where most Bellevue military, contractor, and dual-state-residency cases live, and that is where our engagement carries the load.

Bellevue sits at the southern edge of the Omaha metropolitan area in Sarpy County — the fastest-growing county in Nebraska, with population growth driven almost entirely by the Offutt Air Force Base economic gravity well. Offutt is home to U.S. Strategic Command, the unified combatant command responsible for all U.S. nuclear forces, global strike capability, missile defense, and strategic deterrence. The 55th Wing operates the RC-135 Rivet Joint, Combat Sent, and Cobra Ball strategic-reconnaissance aircraft fleet alongside the E-4B Nightwatch — the National Airborne Operations Center, often called the “Doomsday Plane,” built to serve as a survivable command post for the Secretary of Defense in a nuclear crisis. The base employs thousands of active-duty Air Force personnel, civilian Department of Defense staff, and cleared contractors working for Northrop Grumman, Boeing, Lockheed Martin, Raytheon, Leidos, General Dynamics IT, and the broader Offutt-orbit defense-industrial ecosystem. The classification footprint — Top Secret / Sensitive Compartmented Information, Q-clearance work tied to nuclear weapons, and the post-2017 IRC § 174 research-and-experimental capitalization regime that hit cleared-research budgets across the DoD contractor base — produces a steady stream of tax-controversy work specific to the Offutt population. Bellevue University, a private military-friendly institution with a substantial online-program footprint, adds an academic 1099 and adjunct-faculty layer. The agricultural Schedule F footprint that historically defined Sarpy County is receding under suburban growth, but corn and soybean operations still ring the city limits.

Your tax rights as a Bellevue Nebraska taxpayer

Three parallel rights frameworks apply when you owe tax in Bellevue. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from the Nebraska Revised Statutes Chapter 77 (revenue and taxation) and the Nebraska Tax Equalization and Review Commission framework at Neb. Rev. Stat. § 77-5001 through § 77-5031. County-level rights apply to Nebraska Inheritance Tax cases under Neb. Rev. Stat. § 77-2001 through § 77-2040, administered by the Sarpy County Treasurer at 1210 Golden Gate Drive, Suite 1130, in Papillion. Active-duty service members at Offutt receive additional protections under the Servicemembers Civil Relief Act (SCRA) and military spouses receive residency protections under the Military Spouse Residency Relief Act (MSRRA). Knowing each of these frameworks is the difference between a clean resolution and a missed 30-day TERC petition window that ends in a Nebraska state tax lien against your Old Towne Bellevue, Twin Creek, or Galvin Heights 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. Nebraska mirrors this through Form 33 Power of Attorney filed with the Department of Revenue.

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 twelve miles north of Bellevue at the Roman L. Hruska Federal Courthouse, 111 South 18th Plaza, Omaha — the same building that houses the U.S. District Court for the District of Nebraska, Omaha Division.

Right to TERC review

Neb. Rev. Stat. § 77-5013 gives you 30 days from a final Nebraska Department of Revenue or county-assessment decision to petition the Nebraska Tax Equalization and Review Commission — an independent state administrative tribunal at 301 Centennial Mall South, 4th Floor, in Lincoln, created under Neb. Rev. Stat. § 77-5005. The 30-day window is materially shorter than the federal 90-day Tax Court deadline. Missing it forfeits the right to administrative review of the state assessment before judicial appeal becomes available.

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 in U.S. Tax Court.

SCRA and MSRRA protections

The Servicemembers Civil Relief Act (SCRA) and the Military Spouse Residency Relief Act (MSRRA, codified at 50 U.S.C. § 4001) protect active-duty service members at Offutt AFB and their spouses from forced Nebraska residency reclassification when assigned away from a home-of-record state. IRS deadlines and collection actions are stayed under IRC § 7508 for combat-zone service. These rules let a Texas-domiciled Air Force captain at Offutt and a Texas-domiciled spouse keep their no-PIT-state residency even after years of Nebraska duty.

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. Nebraska runs a parallel compromise program at the Department of Revenue under Neb. Rev. Stat. § 77-378, requiring full return-filing compliance and a documented financial-disclosure package.

How Victory Tax Lawyers helps Bellevue 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 Bellevue taxpayers, a federal OIC does not resolve Nebraska state liability; we run a parallel Nebraska DOR compromise filing under Neb. Rev. Stat. § 77-378 where the state debt is real. Active-duty Offutt service members may qualify for streamlined consideration when deployment income, combat-zone service, or PCS-driven dual-state filing distorts the financial picture.

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 — an under-used resolution path for Bellevue taxpayers carrying between $50,000 and $250,000 in federal debt, particularly cleared defense contractors whose IRC § 174 research-cost capitalization drove a four-year underpayment cycle and Offutt-orbit senior military families whose deferred-compensation cliffs caught up with them.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Bellevue property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Sarpy County Register of Deeds encumber title on Old Towne, Twin Creek, Galvin Heights, Olde Towne, Avery, and Cornhusker Road properties. The IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing and with any related PCS move-out date for an active-duty family.

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. Bank levies at the Offutt AFB Federal Credit Union, U.S. Bank, First National Bank of Omaha, and Pinnacle Bank are the most common targets for Bellevue residents. Nebraska state tax liens follow a parallel track under Neb. Rev. Stat. § 77-2710, filed with the county clerk — for Bellevue residents, that is the Sarpy County Register of Deeds.

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), Offutt Air Force Base combat-zone exclusion under IRC § 112, classified-research IRC § 174 capitalization positions, Q-clearance and Top Secret / SCI defense-contractor compensation issues, MSRRA spouse-residency determinations, and Nebraska Inheritance Tax controversies tied to estate-administration audits at the Sarpy County level. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Omaha trial sessions are held at the Roman Hruska Courthouse on 18th Plaza, twelve miles north of Bellevue.

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. IRC § 7508 deadline-suspension rules for combat-zone service and IRC § 7508A presidentially declared disaster rules can independently establish reasonable cause for Offutt deployed personnel. Nebraska penalties under Neb. Rev. Stat. § 77-2715.07 follow a separate reasonable-cause analysis applied by the Department of Revenue.

Twelve types of Bellevue tax matters we handle

Federal cases for Bellevue residents and Sarpy County businesses, framed against the Nebraska DOR and Sarpy County overlay where it matters.

Offutt AFB active-duty military cases

Offutt is home to U.S. Strategic Command (USSTRATCOM), the unified combatant command for all U.S. nuclear forces, and the 55th Wing, the largest wing in Air Combat Command. IRC § 112 excludes combat-zone compensation from gross income for active-duty service members in designated zones. IRC § 7508 suspends IRS filing and collection deadlines for combat-zone or qualified hazardous-duty area service. The Servicemembers Civil Relief Act (SCRA) preserves home-of-record state residency for income-tax purposes regardless of duty station, and the Military Spouse Residency Relief Act (MSRRA, 50 U.S.C. § 4001) extends the same protection to a service member's spouse. Many Offutt active-duty families maintain Texas, Florida, Washington, or Tennessee residency (no-PIT states) for the entirety of an Offutt tour.

USSTRATCOM and 55th Wing senior-officer compensation

USSTRATCOM is one of the most strategically sensitive commands in the Department of Defense, with general-officer leadership at the rank of admiral or four-star general (the Commander reports directly to the Secretary of Defense). Flag-officer compensation includes Basic Pay, Basic Allowance for Housing (BAH, untaxed under IRC § 134), Basic Allowance for Subsistence (BAS, untaxed), aviator pay, hazardous-duty pay for nuclear-operations qualifications, and post-retirement transition issues that often involve a move into the cleared-contractor space. The interaction with the federal civilian-employment retirement system (FERS) for high-rank transitions into the Senior Executive Service drives a wave of mid-to-late-career federal tax controversies.

Defense-contractor IRC § 174 capitalization disputes

The post-2017 TCJA amendment to IRC § 174 forced capitalization (rather than current expensing) of research-and-experimental expenditures starting in 2022. Cleared defense contractors at Offutt — Northrop Grumman, Boeing, Lockheed Martin, Raytheon, Leidos, General Dynamics IT, CACI, SAIC, and the broader Offutt-orbit contractor ecosystem — absorbed substantial cash-tax increases on classified-research programs supporting USSTRATCOM, the 55th Wing reconnaissance fleet, the E-4B Nightwatch program, and the broader strategic-deterrence portfolio. Audit exposure on what counts as § 174 research expenditure versus current-year operating expense remains active, and the K-1 or W-2 effect on senior contractor personnel hits hard.

Top Secret / SCI clearance and Q-clearance compensation

Cleared workforce at Offutt earns substantial clearance premiums — Top Secret / Sensitive Compartmented Information (TS/SCI) is the standard, with Q-clearance (DOE nuclear-weapons information access) layered on top for personnel touching the nuclear-strike portfolio. Equity compensation, deferred-compensation arrangements under IRC § 409A, sign-on bonuses, retention bonuses, and clearance-renewal incentives all flow through W-2 wages or K-1 distributions with distinct tax-timing exposure. We coordinate audit responses without disclosing classified work content, working from unclassified W-2 and K-1 reporting.

MSRRA military-spouse residency cases

The Military Spouse Residency Relief Act (50 U.S.C. § 4001) lets a military spouse elect the service member's home-of-record state as the spouse's tax residency, even if the spouse has never lived there. Bellevue has one of the largest military-spouse populations in Nebraska, with thousands of Offutt-stationed families. The election is filed annually on state W-4 equivalent forms, and Nebraska's processing of MSRRA elections can be inconsistent. When the Nebraska DOR assesses a military spouse who properly elected another state, the protest goes through DOR administrative review and, if needed, to TERC under the 30-day petition window of Neb. Rev. Stat. § 77-5013.

Nebraska Inheritance Tax controversies

Nebraska is one of the very few states with a county-administered inheritance tax under Neb. Rev. Stat. § 77-2001, with rates of 1% for immediate-family heirs (spouse exempt; children, parents, siblings at 1% above an exemption amount), 11% for more remote relatives, and 15% to 18% for non-relatives. The tax is administered by the Sarpy County Treasurer at 1210 Golden Gate Drive, Suite 1130, in Papillion, for Bellevue-domiciled estates and is separate from any federal estate-tax exposure under IRC § 2001. Estate audits regularly surface IRC § 1014 stepped-up-basis questions on inherited farmland and family-business interests held by Sarpy County decedents.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Bellevue restaurant owners along Mission Avenue and Cornhusker Road, Sarpy County small-business operators serving the Offutt-orbit contractor base, and tradespeople in the Twin Creek and Avery commercial corridors are the most common targets. The IRS uses Form 4180 interviews to identify responsible persons; the Nebraska DOR applies a parallel responsible-person rule to withheld state PIT under Neb. Rev. Stat. § 77-2705.

Notice of Federal Tax Lien

NFTLs filed with the Sarpy County Register of Deeds encumber title and trigger CDP rights under IRC § 6320. A parallel Nebraska state tax lien may be filed under Neb. Rev. Stat. § 77-2710. Old Towne Bellevue, Twin Creek, Galvin Heights, Olde Towne, and Cornhusker Road refinances and sales stall fast when an NFTL hits the title search. For active-duty Offutt families facing a PCS move, an NFTL on the Bellevue home complicates the sale; we coordinate Form 14135 discharge with the closing timeline.

IRS bank or wage levy

Bank levies on accounts at the Offutt AFB Federal Credit Union, First National Bank of Omaha, U.S. Bank, Wells Fargo, Pinnacle Bank, and Bank of America. Wage levies hit Offutt-orbit contractor employers and Sarpy County businesses within days of CP90 or LT11 issuance — Northrop Grumman, Boeing, Lockheed Martin, Raytheon, Leidos, General Dynamics IT, Bellevue University, and the larger Sarpy County employer base all process IRS wage levies regularly. Active-duty pay through DFAS is also subject to federal levy after CDP rights have run.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. Active-duty military are exempt under the statute, but cleared contractors, retired military, and Department of State personnel attached to USSTRATCOM are not. For a defense contractor whose work requires international travel to allied-command sites, a passport revocation can be career-ending. Form 14794 resolves the revocation once the debt is brought into compliance or under an active payment plan.

FBAR and FATCA non-disclosure

FinCEN Form 114 for foreign accounts over $10,000 aggregate. Bellevue's significant active-duty military population includes service members and spouses with prior duty stations in Europe, Japan, Korea, the Middle East, and the Pacific — producing steady FBAR exposure on overseas accounts opened during PCS tours. Filipino-American and other Asian-American community members in Sarpy County maintain home-country accounts that also create FBAR obligations. The IRS Streamlined Filing Compliance Procedures are a frequent engagement for first-time disclosures, and the procedures provide a path for taxpayers whose non-filing was non-willful.

Bellevue University 1099 faculty and online-program cases

Bellevue University is a private military-friendly institution with a substantial online-program footprint serving active-duty military and veterans across the country. Adjunct faculty, online instructors, and curriculum-development consultants typically receive Form 1099-NEC for teaching income, with Schedule C reporting and self-employment tax exposure under IRC § 1401. Estimated-tax shortfalls under IRC § 6654 are common when a faculty member transitions from W-2 employment to 1099 adjunct work mid-year. Multi-state filing exposure follows online instruction across state lines.

Nine common causes of tax debt for Bellevue taxpayers

Patterns we see repeatedly in Bellevue engagements. None of them are unusual — all of them are resolvable.

1. PCS-move dual-state filing

An active-duty Offutt family arrives mid-year from a prior duty station, files Nebraska part-year resident, and discovers the prior state's revenue department is assessing tax through year-end. SCRA preserves home-of-record state residency, but state revenue departments often require an affirmative election and supporting documentation. Without a clean SCRA filing, dual-state assessment is the default outcome.

2. Contractor self-employment underpayment

Cleared defense contractors who shift from W-2 employment with a prime contractor to 1099 consulting work for a smaller cleared shop file Schedule C income with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654. Bellevue University adjuncts and online instructors face the same pattern.

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 post-2020 Sarpy County restaurant turnover along Mission Avenue and the small-shop contractor consolidations that followed the 55th Wing modernization spending cycle.

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. Common in active-duty divorces where one spouse handled all tax filings and the other had no awareness of underreported contractor 1099 income or undisclosed cryptocurrency activity.

5. Combat-zone deadline confusion

IRC § 7508 suspends IRS filing and collection deadlines for active-duty service in a combat zone or qualified hazardous-duty area. Deployed Offutt RC-135 crews, Air Force special-operations integrators attached to USSTRATCOM, and 55th Wing personnel rotating through Middle East and Pacific theaters often miss the post-deployment 180-day extension window because the unit's tax-assistance briefing didn't cover it.

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. Bellevue's tech-adjacent contractor population picked up substantial crypto exposure through 2021-2024, and the IRS computer matching against Form 1099-DA continues to surface omissions.

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. Nebraska follows a three-year refund bar under Neb. Rev. Stat. § 77-2786. Deployed military families who relied on a non-deployed spouse for filings often surface multi-year delinquencies after a PCS.

8. Real-estate sale without estimated tax

An Old Towne Bellevue, Twin Creek, Galvin Heights, or Cornhusker Road property sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Active-duty families who sell during PCS often miss the IRC § 121 home-sale exclusion when the use-test is interrupted by deployment, even though IRC § 121(d)(9) extends the test for qualified official extended duty.

9. Post-retirement contractor transition

An Offutt USSTRATCOM or 55th Wing senior officer retires and transitions into a cleared-contractor role with Northrop Grumman, Boeing, Lockheed Martin, Raytheon, Leidos, or General Dynamics IT. Military pension flows under one set of withholding rules; civilian contractor W-2 or K-1 income flows under another. The first year of the transition routinely produces a five-figure balance due as withholding rates lag the new compensation level.

Eight tax liabilities that pull in Bellevue taxpayers

Federal authority alongside the Nebraska 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 Nebraska mirror at Neb. Rev. Stat. § 77-2715.07 imposes a 5%/month late-filing penalty on unpaid Nebraska tax, capped at 25%. IRC § 7508 suspends these deadlines for active-duty service in combat-zone or qualified hazardous-duty areas.

Failure to file Nebraska state return

Neb. Rev. Stat. § 77-2715.07 imposes the late-filing penalty on unpaid Nebraska PIT, plus interest under Neb. Rev. Stat. § 77-2784. The Department of Revenue may issue a Notice of Deficiency triggering the 60-day informal-review window followed by a 30-day TERC petition window under Neb. Rev. Stat. § 77-5013. The graduated 2.46% to 5.84% PIT rate is phasing down to 3.99% by 2027 under LB873.

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. Active-duty military pay is calculated into Reasonable Collection Potential differently when combat-zone exclusion or hazardous-duty pay is in the mix.

Nebraska sales-tax delinquency

Neb. Rev. Stat. § 77-2701 sets the 5.5% state sales tax. Bellevue adds a 1.5% local stack, bringing the combined Bellevue sales tax to 7% on most transactions. Neb. Rev. Stat. § 77-2705 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. Nebraska applies a parallel responsible-person rule to withheld state PIT under Neb. Rev. Stat. § 77-2705.

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. For IRC § 174 capitalization disputes affecting cleared defense contractors, substantial-authority defense rests on the still-developing post-TCJA regulatory record.

Nebraska Corporate Income Tax

Neb. Rev. Stat. § 77-2734.02 imposes the 5.84% Nebraska Corporate Income Tax, phasing down on a parallel schedule with the personal income tax under LB873. Single-sales-factor apportionment produces favorable results for Sarpy County-based businesses with national or international defense-contracting revenue.

Nebraska Inheritance Tax

Neb. Rev. Stat. § 77-2001 through § 77-2040 imposes a county-administered inheritance tax with rates of 1% for immediate-family heirs (above an exemption amount; spouse exempt), 11% for more remote relatives, and 15% to 18% for non-relatives. The tax is filed and paid in the county where the decedent was domiciled — for Bellevue estates, the Sarpy County Treasurer at 1210 Golden Gate Drive, Suite 1130, Papillion. There is no state estate tax in Nebraska; the inheritance tax fills that role and is structurally unique among U.S. tax regimes.

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 — including IRC § 7508 combat-zone service.

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 Sarpy County Register of Deeds.

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, the Nebraska Department of Revenue, the Sarpy County Treasurer, and the Nebraska Tax Equalization and Review Commission.

Why Victory Tax Lawyers for a Bellevue federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Nebraska-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 Omaha at the Roman L. Hruska Federal Courthouse on 18th Plaza, twelve miles north of Bellevue. 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 Bellevue clients never need a separately admitted Nebraska attorney because the case is, at its core, federal — and an unusually large share of the Bellevue case mix is military-federal, defense-contractor-federal, or USSTRATCOM-orbit federal work that has no Nebraska state-tax exposure at all once the SCRA and MSRRA elections are properly filed.

For administrative work before the Nebraska Department of Revenue — protests, audit responses, compromise submissions under Neb. Rev. Stat. § 77-378, and installment-agreement requests — we file Nebraska Form 33 Power of Attorney and handle the matter remotely. When a case must move to the Nebraska Tax Equalization and Review Commission (the state's independent administrative tribunal at 301 Centennial Mall South, 4th Floor, in Lincoln) under the 30-day window in Neb. Rev. Stat. § 77-5013, or appeal further to the Nebraska Court of Appeals or the Nebraska Supreme Court, we coordinate with locally admitted Nebraska counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure given the Offutt military-and-contractor base, 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 Nebraska-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Bellevue 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, and active-duty deployed personnel can sign engagement letters and Form 2848 from any duty station.

Our seven-step process for Bellevue clients

Free consultation

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

Engagement letter

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

Form 2848 and CAF

We file the federal Power of Attorney with the IRS and Nebraska Form 33 with the Nebraska DOR, register on the CAF system, and step in as the contact of record.

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events — including IRC § 7508 combat-zone suspension.

Strategy memo

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

Filing and negotiation

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

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 Nebraska assessment limits

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. For active-duty Offutt service members, IRC § 7508 independently suspends the running of all IRS deadlines during combat-zone or qualified hazardous-duty area service, plus a 180-day post-deployment grace period.

Nebraska runs a parallel state collection rule under Neb. Rev. Stat. § 77-2786 and § 77-2793: the Department of Revenue must assess Nebraska income tax within three years of the return due date (six years for substantial understatement of gross income exceeding 25%, with no statute on assessment in cases of fraud or non-filing). Once assessed, the Nebraska collection right runs under Neb. Rev. Stat. § 77-2710, which provides for a state tax lien continuing until paid or extinguished by the taxpayer's discharge in bankruptcy. Many Bellevue taxpayers carry a federal CSED that will run out before the Nebraska lien is released — making the state debt the longer-term collection exposure. Pull both records and know the dates before agreeing to any payment plan or amended return that could restart a clock. For Nebraska Inheritance Tax assessments at the county level, the Sarpy County Treasurer runs collection under the inheritance-tax statutes at Neb. Rev. Stat. § 77-2001 through § 77-2040 on a separate timeline.

Bellevue tax authorities and venues

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

Internal Revenue Service — Omaha Taxpayer Assistance Center

The federal tax authority, at irs.gov. The closest IRS Taxpayer Assistance Center to Bellevue is the Omaha TAC at 1616 Capitol Avenue, Suite 200, Omaha NE 68102, approximately twelve miles north of downtown Bellevue. Appointments required.

U.S. Tax Court — Omaha trial sessions

The U.S. Tax Court holds regular trial sessions twelve miles north of Bellevue at the Roman L. Hruska Federal Courthouse, 111 South 18th Plaza, Omaha NE 68102. Petitions are filed at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

Nebraska Department of Revenue

The state tax authority, at revenue.nebraska.gov. Headquartered at 301 Centennial Mall South, 5th Floor, Lincoln NE 68509. Administers the graduated 2.46% to 5.84% personal income tax under Neb. Rev. Stat. § 77-2715.01, the 5.84% Corporate Income Tax under Neb. Rev. Stat. § 77-2734.02, the 5.5% state sales tax under Neb. Rev. Stat. § 77-2701, withholding tax, and the Nebraska compromise authority under Neb. Rev. Stat. § 77-378.

Nebraska Tax Equalization and Review Commission

The state's independent administrative tribunal that hears tax appeals from the Department of Revenue and county assessment boards. Created under Neb. Rev. Stat. § 77-5005. Seated at 301 Centennial Mall South, 4th Floor, Lincoln NE 68509. Page: terc.nebraska.gov. The 30-day petition deadline under Neb. Rev. Stat. § 77-5013 runs from the Department of Revenue's final decision. TERC decisions are appealable to the Nebraska Court of Appeals.

Sarpy County Treasurer

Sarpy County collects real-estate and personal-property taxes for Bellevue, Papillion, La Vista, Gretna, and Springfield, and administers the Nebraska Inheritance Tax under Neb. Rev. Stat. § 77-2001 for Sarpy County-domiciled estates. Office at 1210 Golden Gate Drive, Suite 1130, Papillion NE 68046. NFTLs affecting Bellevue real estate are recorded with the Sarpy County Register of Deeds at the same complex. Sarpy County is the fastest-growing county in Nebraska, with population growth driven by Offutt AFB and the surrounding defense ecosystem.

Sarpy County Assessor

Sets the assessed value for real and personal property within Sarpy County. Office at 1210 Golden Gate Drive, Suite 2155, Papillion NE 68046. Property valuation protests run through the County Board of Equalization, with further appeal to TERC under Neb. Rev. Stat. § 77-5013. Property-tax protests share the 30-day TERC clock with income-tax appeals.

City of Bellevue Finance Department

The municipal finance authority for the City of Bellevue. Office at 210 West Mission Avenue, Bellevue NE 68005. Administers city-level occupation taxes, business licenses, and certain user fees. Bellevue does not impose a municipal wage or earnings tax — the city-level exposure runs primarily through occupation taxes on specific business categories and the 1.5% local sales-tax stack on top of the 5.5% Nebraska state rate.

U.S. District Court — District of Nebraska, Omaha 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 for the District of Nebraska, Omaha Division, located at the Roman L. Hruska Federal Courthouse, 111 South 18th Plaza, twelve miles north of Bellevue, 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. Bellevue cases run through the Appeals offices serving the central United States. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Taxpayer Advocate Service — Nebraska

An independent organization within the IRS that helps when normal channels stall. The Nebraska Local Taxpayer Advocate office serves taxpayers across Nebraska and parts of Iowa from the Omaha federal building footprint. Page: taxpayeradvocate.irs.gov.

Speak with a tax attorney about your Bellevue matter

Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, a Nebraska DOR Notice of Assessment, or a Sarpy County inheritance-tax billing is in front of you, the deadline to respond is real and short — call today.

Call (800) 883-8301 Free Consultation

Frequently asked questions — Bellevue Nebraska tax

I am stationed at Offutt Air Force Base — what tax protections apply to me?

Active-duty service members at Offutt receive several federal protections that materially change the tax calculus. IRC § 112 excludes combat-zone compensation from gross income for any month in which the service member served in a designated combat zone. IRC § 7508 suspends the running of IRS filing, payment, assessment, and collection deadlines during combat-zone service plus a 180-day post-deployment grace period. The Servicemembers Civil Relief Act (SCRA) preserves home-of-record state residency for income-tax purposes regardless of duty station, allowing a Texas-domiciled or Florida-domiciled service member at Offutt to keep that no-PIT state's residency. The Military Spouse Residency Relief Act (MSRRA, 50 U.S.C. § 4001) extends the same residency protection to a service member's spouse. The Nebraska DOR processes these elections through annual employer withholding paperwork; when the DOR assesses a service member or spouse who properly elected another state, the protest goes through DOR administrative review and, if needed, to TERC under the 30-day window of Neb. Rev. Stat. § 77-5013.

I work for a defense contractor at Offutt — how does IRC § 174 affect my compensation?

The post-2017 TCJA amendment to IRC § 174 forced capitalization (rather than current expensing) of research-and-experimental expenditures starting in tax year 2022. Cleared defense contractors supporting USSTRATCOM and the 55th Wing — Northrop Grumman, Boeing, Lockheed Martin, Raytheon, Leidos, General Dynamics IT, CACI, SAIC, and the broader Offutt-orbit base — absorbed substantial cash-tax increases on classified-research programs. The effect on individual employee tax exposure depends on entity structure: at a publicly traded prime contractor the impact runs through corporate tax filings, while at a flow-through S-corp or partnership the K-1 income passed through to owner-employees rises in the year of capitalization. We help senior contractor personnel understand the K-1 impact, defend audit positions on what counts as a § 174 expenditure versus a current-year operating expense, and resolve the resulting balance-due exposures through IRC § 6159 installment agreements or IRC § 7122 Offers in Compromise where the facts support relief.

My spouse is active-duty at Offutt and I'm a Texas resident — do I owe Nebraska tax?

If you properly elect Texas residency under the Military Spouse Residency Relief Act (MSRRA, 50 U.S.C. § 4001), Nebraska may not tax your wage income earned at a Bellevue or Omaha employer. The election requires that you share your service-member spouse's home-of-record state, that you are present in Nebraska solely because of your spouse's military orders, and that you affirm the election on Nebraska employer withholding paperwork (typically with a Nebraska Form W-4N or equivalent annual filing). When properly executed, MSRRA lets a Texas-domiciled military spouse work at any Bellevue or Omaha employer (including the major hospitals, Bellevue University, Offutt-orbit defense contractors, or the City of Bellevue itself) and pay no Nebraska PIT on those wages — the wages remain Texas-source income, and Texas has no personal income tax.

What is the Nebraska Inheritance Tax and why does Sarpy County administer it?

Nebraska is one of a small handful of U.S. states (alongside Iowa, Kentucky, Maryland, New Jersey, and Pennsylvania) that imposes an inheritance tax rather than — or in addition to — a state estate tax. Nebraska has no state estate tax. Instead, under Neb. Rev. Stat. § 77-2001 through § 77-2040, the state imposes a county-administered inheritance tax on transfers from a deceased Nebraska resident, with rates depending on the heir's relationship to the decedent: 1% for immediate family above an exemption amount (spouse is fully exempt), 11% for more remote relatives, and 15% to 18% for non-relatives. The tax is filed and collected at the county level — for Bellevue estates, the Sarpy County Treasurer at 1210 Golden Gate Drive, Suite 1130, Papillion. This county-administered structure is materially unusual in U.S. tax law and creates an administrative overlay distinct from federal estate-tax planning under IRC § 2001 and stepped-up basis under IRC § 1014.

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

The U.S. Tax Court holds regular trial sessions in Omaha, twelve miles north of Bellevue, at the Roman L. Hruska Federal Courthouse, 111 South 18th Plaza, Omaha NE 68102. A Bellevue taxpayer can request the Omaha 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. For active-duty service members deployed in a combat zone at the time of the Notice, IRC § 7508 extends the 90-day period by the duration of deployment plus 180 days.

What is TERC and what is its deadline?

The Nebraska Tax Equalization and Review Commission (TERC) is an independent state administrative tribunal that hears tax appeals from the Department of Revenue and county boards of equalization. It was created under Neb. Rev. Stat. § 77-5005 and sits at 301 Centennial Mall South, 4th Floor, in Lincoln. The petition deadline is 30 days from a final Department of Revenue or county-board decision under Neb. Rev. Stat. § 77-5013 — materially shorter than the federal 90-day Tax Court deadline. TERC decisions are further appealable to the Nebraska Court of Appeals within the time allowed by Nebraska appellate rules. Victory Tax Lawyers refers TERC litigation to locally admitted Nebraska counsel; we handle the Department of Revenue administrative phase directly under Nebraska Form 33 Power of Attorney.

I hold a Top Secret / SCI clearance — can a tax case affect my clearance?

Unresolved tax debt is one of the most common reasons for a clearance reinvestigation finding under Security Executive Agent Directive (SEAD) 4, Adjudicative Guideline F (Financial Considerations). The Defense Counterintelligence and Security Agency (DCSA, formerly DSS) and the Department of Energy (for Q-clearance work touching nuclear weapons) review financial behavior including unpaid federal or state tax liabilities, IRS liens, and wage levies. Resolving the debt through an Installment Agreement, an Offer in Compromise, or Currently Not Collectible status — and documenting the resolution — restores the financial-considerations posture. We coordinate engagement timing with clearance-renewal cycles when the calendar matters.

What is Nebraska's collection statute of limitations?

Neb. Rev. Stat. § 77-2786 and § 77-2793 give the Department of Revenue three years from a return's due date to assess Nebraska income tax (six years for substantial understatement of gross income exceeding 25%, with no limit for fraud or unfiled returns). Once an assessment is final and a state tax lien has been filed under Neb. Rev. Stat. § 77-2710, Nebraska's collection right continues until the debt is paid or extinguished by the taxpayer's discharge in bankruptcy or operation of law. This is materially different from the federal IRC § 6502 ten-year CSED. A Bellevue taxpayer whose federal CSED expires may still face an active Nebraska state tax lien for the same tax year.

Can I be audited by both the IRS and the Nebraska DOR for the same year?

Yes. The IRS and the Nebraska Department of Revenue operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to Nebraska under the state's federal-change reporting rule, and vice versa. A Bellevue resident's federal adjustment may further trigger a Sarpy County review of inheritance-tax exposure where an estate matter is open. We coordinate the audits to prevent inconsistent positions on the federal record from costing you on the Nebraska return.

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

Yes. The Nebraska Department of Revenue accepts compromise offers under its compromise authority at Neb. Rev. Stat. § 77-378. The Department 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 Nebraska returns must be filed before consideration, and a financial-disclosure package is required. We typically run a Nebraska compromise filing in parallel with the federal Offer where both debts are real.

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

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 Omaha. For Nebraska DOR administrative work, we file Nebraska Form 33 Power of Attorney and handle the matter remotely. For formal litigation at the Nebraska Tax Equalization and Review Commission, the Nebraska Court of Appeals, or the Nebraska Supreme Court, we co-counsel with locally admitted Nebraska attorneys. Most engagements — audit defense, OIC, IA, levy release, Tax Court — are federal and stay entirely with our firm. For active-duty military and federal civilian employees stationed at Offutt, the federal-only engagement is usually the cleanest path because SCRA and MSRRA strip away the state-tax layer entirely.

I retired from Offutt and moved into a contractor role — what tax issues should I expect?

The transition from active-duty military pay to civilian contractor compensation routinely produces a five-figure balance due in the first full civilian tax year. Military pension under DFAS uses one set of federal withholding tables; civilian contractor W-2 or K-1 income at Northrop Grumman, Boeing, Lockheed Martin, Raytheon, Leidos, or General Dynamics IT uses a different one, and the new compensation level (commonly $150,000 to $300,000 for a retired senior officer moving into a cleared-contractor role at Offutt) puts the taxpayer into the 32% or 35% federal marginal bracket where the 22% supplemental withholding rate on bonuses no longer covers the liability. Nebraska 5.84% PIT layered on top compounds the spread. We help retired military families recalibrate withholding through Form W-4 adjustments, file the first-year balance through an Installment Agreement under IRC § 6159 where the cash flow doesn't support full payment, and pursue First-Time Abate relief under IRM 20.1.1 where the late payment was driven by transition timing.

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). Nebraska follows a parallel filing-compliance posture; the Department of Revenue may assess based on the federal-change reporting rule or estimate tax when a taxpayer fails to file. For deployed military families who lost track of multiple filing years during back-to-back overseas tours, IRC § 7508 may suspend the deadlines for the affected years — we calculate the suspension carefully because it changes the order in which filings should be made.

Can the IRS levy my Bellevue 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 the Offutt AFB Federal Credit Union, First National Bank of Omaha, Mutual of Omaha Bank, Pinnacle Bank, U.S. Bank, Wells Fargo, JPMorgan Chase, or any Nebraska-chartered institution and serve wage levies on Bellevue and Sarpy County employers including the major Offutt-orbit defense contractors, Bellevue University, the City of Bellevue, and Sarpy County itself. Active-duty pay through DFAS may also be levied after CDP rights have run. 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). The Nebraska DOR issues parallel state tax liens under Neb. Rev. Stat. § 77-2710.

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 Nebraska compromise filing under Neb. Rev. Stat. § 77-378 typically runs four to nine months on a parallel track.

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: May 25, 2026. Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Nebraska statute citation references the Nebraska Revised Statutes. 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 Nebraska Department of Revenue, the Sarpy County Treasurer, the U.S. Tax Court, the Nebraska Tax Equalization and Review Commission, 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 Nebraska; where a Nebraska state-court appearance or TERC 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.

Authorities cited on this page

26 U.S.C. § 7122 — Federal Offer in Compromise
26 U.S.C. § 6159 — Installment Agreements
26 U.S.C. § 6321 — Federal Tax Lien
26 U.S.C. § 6325 — Lien Release and Discharge
26 U.S.C. § 6331 — Levy and Distraint
26 U.S.C. § 6343 — Release of Levy
26 U.S.C. § 6502 — Collection Statute Expiration
26 U.S.C. § 6213 — Tax Court Petition Window
26 U.S.C. § 6320 — CDP for Liens
26 U.S.C. § 6330 — CDP for Levies
26 U.S.C. § 6651 — Failure-to-File and Failure-to-Pay
26 U.S.C. § 6672 — Trust Fund Recovery Penalty
26 U.S.C. § 6015 — Innocent Spouse Relief
26 U.S.C. § 7345 — Passport Revocation
26 U.S.C. § 112 — Combat-zone compensation exclusion
26 U.S.C. § 7508 — Combat-zone deadline suspension
26 U.S.C. § 174 — Research and experimental expenditures
26 U.S.C. § 121 — Home-sale exclusion (military extension under § 121(d)(9))
26 U.S.C. § 134 — Military qualified housing and subsistence allowances
26 U.S.C. § 1014 — Stepped-up basis at death
26 U.S.C. § 2001 — Federal estate tax
50 U.S.C. § 4001 — Military Spouse Residency Relief Act (MSRRA)
Neb. Rev. Stat. § 77-2001 through § 77-2040 — Nebraska Inheritance Tax (county-administered)
Neb. Rev. Stat. § 77-2701 — Nebraska state sales and use tax (5.5%)
Neb. Rev. Stat. § 77-2705 — Nebraska sales-tax and withholding responsible-person liability
Neb. Rev. Stat. § 77-2710 — Nebraska state tax lien
Neb. Rev. Stat. § 77-2715.01 — Nebraska graduated personal income tax (top rate phasing to 3.99% under LB873)
Neb. Rev. Stat. § 77-2715.07 — Nebraska failure-to-file and failure-to-pay penalties
Neb. Rev. Stat. § 77-2734.02 — Nebraska Corporate Income Tax (top rate 5.84%, phasing down)
Neb. Rev. Stat. § 77-2784 — Nebraska interest on unpaid tax
Neb. Rev. Stat. § 77-2786 — Nebraska assessment statute of limitations
Neb. Rev. Stat. § 77-2793 — Nebraska deficiency assessment
Neb. Rev. Stat. § 77-378 — Nebraska compromise authority
Neb. Rev. Stat. § 77-5005 — Nebraska Tax Equalization and Review Commission (creation)
Neb. Rev. Stat. § 77-5013 — TERC petition window (30 days)