Tax Attorney in Boston, MA

Federal IRS representation for Boston individuals and businesses — audits, back taxes, liens, levies, payroll-tax disputes, and U.S. Tax Court litigation at the John W. McCormack Post Office and Courthouse on Post Office Square. We also coordinate Massachusetts Department of Revenue matters under Form M-2848 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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If you owe back taxes in Boston, here is the 2026 picture

Massachusetts is the rare state that pairs a flat 5% personal income tax rate (M.G.L. Ch 62 § 4(b)) with a steep additional 4% surcharge on taxable income above $1 million — the Fair Share Amendment, M.G.L. Ch 62 § 4(d), passed by ballot in 2022 and effective tax year 2023. The combined top state rate for a Boston earner crossing the $1 million mark is 9% on every dollar above the threshold. Stack that on the 37% federal top rate and a Kendall Square biotech founder cashing a §83(b)-elected equity grant or a Fidelity portfolio manager exercising deferred compensation can face an effective marginal rate close to 46%. The Massachusetts estate tax sets the exemption at just $2 million per estate — far below the $13.61 million federal exemption — making Massachusetts one of seventeen states (plus the District of Columbia) that still imposes a state-level estate tax.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the Massachusetts Department of Revenue 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 Form M-2848 with the MA DOR, and put administrative brakes on collection while the case is built.

Federal tax representation for Boston 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 Boston at the John W. McCormack Post Office and Courthouse, 5 Post Office Square. Boston is the primary U.S. Tax Court trial city for all of New England, drawing petitioners from Maine, New Hampshire, Vermont, Rhode Island, and western Massachusetts. From our Robertson Boulevard office in Los Angeles, we represent Boston residents and Massachusetts-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 Massachusetts state tax matters — the flat 5% personal income tax under M.G.L. Ch 62 § 4(b), the 4% Millionaires Tax surcharge on income above $1 million under M.G.L. Ch 62 § 4(d), the 8% corporate excise tax under M.G.L. Ch 63 § 39, the 6.25% state sales-and-use tax, withholding-tax assessments, or contested matters headed to the Massachusetts Appellate Tax Board — we file Form M-2848 with the Department of Revenue and handle the administrative track directly. For formal litigation before the Massachusetts Appellate Tax Board (the state's specialized administrative tax tribunal, established 1930 under M.G.L. Ch 58A and the oldest dedicated state tax tribunal in the United States) or in the Suffolk Superior Court Tax Track, we refer to locally admitted Massachusetts counsel under a co-counsel arrangement. The federal layer is where most Boston high-income, biotech-founder, and equity-compensation cases live, and that is where our engagement carries the load.

Boston sits at the center of one of the most concentrated high-income economies in the country. Kendall Square in Cambridge — one square mile across the Charles River from MIT — holds the densest cluster of biotechnology companies in the world: Moderna headquarters, Biogen Cambridge headquarters, Vertex Pharmaceuticals, Sarepta Therapeutics, Bluebird Bio, Genzyme (now Sanofi), the Pfizer Cambridge campus, and the U.S. Astellas Pharma site. Add Fidelity Investments (headquartered on Summer Street), State Street Corporation (One Lincoln Street), Wellington Management, Bain Capital, Putnam Investments, Eaton Vance (now part of Morgan Stanley), Liberty Mutual, John Hancock, Goodwin Procter, Ropes & Gray, the Mass General Brigham hospital system, Harvard University, MIT, and the Boston Bruins, Celtics, and Red Sox payroll — and you have a tax-resolution footprint that is essentially equity-compensation, RSU underwithholding, ISO disqualifying dispositions, §83(b) elections, §1202 qualified small-business stock claims, §174 R&D capitalization, §1061 carried-interest holding periods, and FBAR work on Portuguese, Brazilian, Irish, Italian, and Vietnamese-American family accounts. The federal procedures are uniform; the facts are Boston-specific.

Your tax rights as a Boston 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 Massachusetts General Laws, the Department of Revenue's published Taxpayer Bill of Rights, and the procedural rules of the Massachusetts Appellate Tax Board. Knowing both is the difference between a clean resolution and a missed 60-day Appellate Tax Board petition window that locks in a state assessment against your Back Bay, Beacon Hill, or South End 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. Massachusetts mirrors this through Form M-2848 Power of Attorney, accepted for all Department of Revenue 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 Boston at the John W. McCormack Post Office and Courthouse, 5 Post Office Square — the primary New England trial city.

Right to Appellate Tax Board review

M.G.L. Ch 58A § 7 gives you 60 days from a final DOR Notice of Assessment to file a petition with the Massachusetts Appellate Tax Board — the state's specialized tax tribunal at 100 Cambridge Street, 2nd Floor, Boston. The 60-day window is shorter than the federal 90-day Tax Court deadline. Missing it forfeits the right to pre-payment review of the state assessment.

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 through the U.S. Tax Court.

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. Massachusetts runs a parallel Offer in Final Settlement program under M.G.L. Ch 62C § 37A administered by the DOR, with similar hardship and insolvency standards. Both programs require all returns filed and current-year compliance 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 Boston 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 Boston taxpayers carrying a parallel Massachusetts liability, we run a separate Offer in Final Settlement filing with the DOR under M.G.L. Ch 62C § 37A on the same financial showing, coordinating the two programs so an accepted federal Offer does not break a pending state offer or vice versa.

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 Boston taxpayers carrying between $50,000 and $250,000 in federal debt, particularly biotech founders who paid AMT on ISO exercises that later went underwater and academic faculty whose §83(b) elections caught up with them.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Boston property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Suffolk County Registry of Deeds encumber title on Beacon Hill, Back Bay, South End, Charlestown, North End, and Seaport District properties; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing date.

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. Massachusetts state tax liens follow a parallel track under M.G.L. Ch 62C § 50 and are recorded in the Registry of Deeds for the county where the taxpayer holds real 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, §83(b) election validity, §1202 Qualified Small Business Stock claims for Kendall Square biotech founders, §174 R&D capitalization timing, and §1061 three-year carried-interest holding periods for Bain Capital and other private-equity partners. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Boston trial sessions are held at the McCormack 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. Massachusetts penalties under M.G.L. Ch 62C § 33 (failure to file) and § 35 (substantial understatement) follow a separate reasonable-cause analysis applied by the DOR and reviewable by the Appellate Tax Board.

Twelve types of Boston tax matters we handle

Federal cases for Boston residents and businesses, framed against the Massachusetts DOR overlay where it matters.

Kendall Square biotech equity compensation

Moderna, Biogen, Vertex, Sarepta, Bluebird, Genzyme/Sanofi, and Pfizer-Cambridge employees hold a mix of RSUs, ISOs, NSOs, and early-stage founder shares with IRC § 83(b) election timing. ISO disqualifying dispositions trigger AMT under IRC § 55; §83(b) elections demand exact 30-day windows; founder shares may qualify for the IRC § 1202 Qualified Small Business Stock exclusion when held five years from original issuance. A single biotech vest year can produce a six- or seven-figure federal balance plus the 9% Massachusetts combined rate on income above $1 million.

Massachusetts Millionaires Tax exposure

M.G.L. Ch 62 § 4(d), effective tax year 2023, adds a 4% surcharge on Massachusetts taxable income above $1 million per filer. Fidelity portfolio managers, Wellington equity partners, Bain Capital carry recipients, Mass General Brigham department chairs, and Bruins, Celtics, and Red Sox players cross the threshold in a single bonus year, exit liquidity event, or playoff run. Estimated-tax planning under IRC § 6654 and the Massachusetts parallel under M.G.L. Ch 62B § 14 becomes a structured engagement, not a checkbox.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Boston restaurant, hospitality, biotech-startup, and construction owners are the most common targets. The IRS uses Form 4180 interviews to identify responsible persons; Massachusetts applies a parallel responsible-person rule to withheld state income tax under M.G.L. Ch 62C § 31A.

Massachusetts estate tax

The Massachusetts estate tax exemption sits at $2 million per estate under M.G.L. Ch 65C — far below the $13.61 million federal exemption for 2024 returns. Massachusetts is one of seventeen states plus the District of Columbia that still imposes a state-level estate tax, and the rate runs up to 16% on the portion above the exemption. A Beacon Hill brownstone, a Wellesley primary residence, a Cape Cod second home, and a Fidelity 401(k) can cross the $2 million Massachusetts threshold without anyone in the family realizing a state filing is required. Form M-706 is due nine months from death.

Notice of Federal Tax Lien

NFTLs filed with the Suffolk County Registry of Deeds encumber title and trigger CDP rights under IRC § 6320. A parallel Massachusetts state tax lien may be recorded under M.G.L. Ch 62C § 50 in the Registry of Deeds for the county where the taxpayer holds real property. Beacon Hill, Back Bay, South End, Charlestown, North End, and Seaport District closings stall fast when an NFTL hits the title search.

IRS bank or wage levy

Bank levies on accounts held at Eastern Bank, Citizens, Bank of America, Santander (Boston is Santander's U.S. headquarters), Cambridge Trust, Rockland Trust, or any Massachusetts-chartered bank. Wage levies hit Boston employers within days of CP90 or LT11 issuance — including Mass General Brigham, Fidelity, State Street, Harvard, MIT, and any Kendall Square biotech.

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 Logan International Airport as a major international gateway and a city full of Harvard, MIT, and Boston University international researchers, dual-citizen Brazilian-American, Portuguese-American, and Irish-American business owners, and Mass General Brigham globally traveling physicians, this lands 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. Boston's Portuguese-American community (Fall River and New Bedford 50 miles south), Brazilian-American population (Allston, Framingham, Somerville), Irish-American families (South Boston, Dorchester), Italian-American families (the North End), Vietnamese community (Fields Corner, Dorchester), and West African community 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.

Short-term rental and real-estate flips

Beacon Hill, Back Bay, North End, Seaport, South End, Cambridge near Harvard Square, and Boston University-adjacent Allston all saw an Airbnb investor wave. IRC § 1031 like-kind exchanges done without a qualified intermediary, dealer-status reclassification under IRC § 1221, STR misclassification under IRC § 280A and the seven-day rule, and the Boston short-term-rental registration requirements all produce assessments. Massachusetts also imposes its 5.7% state-level room-occupancy excise on STRs under M.G.L. Ch 64G, separate from the federal income-tax characterization.

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 — common in divorces involving Mass General Brigham physicians with side practices, biotech executives with concentrated equity, and Bain Capital and other private-equity partners whose K-1 income surprised the other spouse.

Defense-contractor and federal-employee tax

Hanscom Air Force Base in Bedford, Raytheon (now part of RTX) in Waltham, L3Harris, General Dynamics Mission Systems, and the Boston-area defense-contracting corridor produce a steady book of W-2 federal-employee cases, security-clearance debt sensitivity, IRC § 174 R&D capitalization disputes for contractors, and 1099 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. Boston's MIT, Harvard, and biotech-adjacent technical population picked up substantial crypto exposure through 2021-2024. Form 1099-DA reporting (effective 2025) drives the matching cases. Massachusetts treats virtual currency gains as ordinary income subject to the 5% flat rate, with the 4% Millionaires Tax surcharge applying once total taxable income crosses $1 million.

Nine common causes of tax debt for Boston taxpayers

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

1. Underwithheld RSU and ISO vest events

A Moderna, Vertex, Fidelity, State Street, Wellington, or Wayfair employee at the 35% or 37% federal marginal bracket sees only 22% supplemental withholding on RSU vests. The shortfall, plus 5% Massachusetts and the 4% Millionaires Tax surcharge once total income clears $1 million, produces a five- or six-figure balance due the following April.

2. Self-employment underpayment

Mass General Brigham attending physicians with private 1099 practices, Harvard and MIT consultants in the federal-funding corridor, Goodwin Procter and Ropes & Gray of-counsel attorneys, 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, S-corp, or early-stage biotech closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Common in the Kendall Square startup-failure cycle, where a Series B miss can leave founders with personal trust-fund exposure.

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. Massachusetts has its own DOR identity-theft hotline that runs in parallel.

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. Massachusetts mirrors the federal three-year refund bar under M.G.L. Ch 62C § 36.

8. Real-estate sale without estimated tax

A Beacon Hill, Back Bay, Cambridge, or South End 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 Boston biotech, financial-services, and tech 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 — especially costly for Kendall Square founders whose early-grant basis was low and whose §1202 QSBS holding period depends on a valid election.

Eight tax liabilities that pull in Boston taxpayers

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

Failure to file federal return

IRC § 6651(a)(1) imposes 5% per month, capped at 25%, plus interest under IRC § 6601. The Massachusetts mirror is M.G.L. Ch 62C § 33 imposing a 1% per month late-filing penalty, capped at 25%, on unpaid Massachusetts tax.

Failure to file Massachusetts return

M.G.L. Ch 62C § 33 imposes a 1% per month penalty on the unpaid tax for failure to file, capped at 25%, plus interest under M.G.L. Ch 62C § 32. The DOR may issue a Notice of Assessment triggering the 60-day Appellate Tax Board petition window under M.G.L. Ch 58A § 7. The 4% Millionaires Tax surcharge under M.G.L. Ch 62 § 4(d) is collected on the same return.

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.

Massachusetts sales-tax delinquency

M.G.L. Ch 64H § 2 sets the 6.25% state sales tax on retail sales of tangible personal property. There is no local-option sales tax stack in Massachusetts — the rate is uniform statewide, simplifying compliance but not exposure. M.G.L. Ch 62C § 31A imposes personal liability on responsible persons for unpaid trust-fund sales tax. The Massachusetts use tax under M.G.L. Ch 64I is aggressively enforced against businesses purchasing equipment out of state.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Massachusetts applies a parallel responsible-person rule to withheld state income tax under M.G.L. Ch 62C § 31A.

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. M.G.L. Ch 62C § 35A imposes a parallel 20% Massachusetts accuracy-related penalty.

Massachusetts estate tax

M.G.L. Ch 65C imposes the Massachusetts estate tax on estates above $2 million per decedent, with a graduated rate scale topping out at 16%. The exemption is one of the lowest in the country — far below the $13.61 million federal exemption — making Massachusetts one of the seventeen estate-tax states plus DC. Form M-706 is filed within nine months of death. Coordination with the federal estate-tax return on Form 706 is its own engagement layer.

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 Suffolk County Registry 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 and the Massachusetts Department of Revenue.

Why Victory Tax Lawyers for a Boston federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Massachusetts-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 Boston at the John W. McCormack Post Office and Courthouse on Post Office Square. IRS administrative practice runs on Form 2848 Power of Attorney, accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Boston clients never need a separately admitted Massachusetts attorney because the case is, at its core, federal.

For administrative work before the Massachusetts Department of Revenue — protests, audit responses, Offer in Final Settlement submissions under M.G.L. Ch 62C § 37A, and installment-agreement requests — we file DOR Form M-2848 Power of Attorney and handle the matter remotely. When a case must move to the Massachusetts Appellate Tax Board (the state's specialized administrative tribunal, established 1930 under M.G.L. Ch 58A, and the oldest dedicated state-tax tribunal in the United States, seated at 100 Cambridge Street, 2nd Floor, Boston) or appeal further to the Massachusetts Appeals Court, we coordinate with locally admitted Massachusetts counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the bigger exposure given Massachusetts' 9% combined top rate on million-dollar earners and tightly enforced trust-fund tax regime, 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 Massachusetts-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Boston 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 travel to Robertson Boulevard.

Our seven-step process for Boston 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 Form M-2848 with the Massachusetts 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.

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 an Appellate Tax Board petition through local counsel — and handle every IRS and 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 Massachusetts' six-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.

Massachusetts runs a parallel state collection rule under M.G.L. Ch 62C § 65: the DOR generally must assess Massachusetts income tax within three years of the return due date (extended to six years for substantial omissions of more than 25% of gross income, with no statute on collection in cases of fraud or non-filing). Once assessed, the DOR's collection right runs for six years from the date of assessment, with renewal possible by re-recording the state tax lien under M.G.L. Ch 62C § 50. Many Boston taxpayers carry a federal CSED that will run out before the Massachusetts 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.

Boston tax authorities and venues

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

Internal Revenue Service — Boston TAC

The federal tax authority, at irs.gov. The Boston Taxpayer Assistance Center operates at the John F. Kennedy Federal Building, 25 New Sudbury Street, Room 100, Boston MA 02203. Appointments required.

U.S. Tax Court — Boston trial sessions

The U.S. Tax Court holds regular trial sessions in Boston at the John W. McCormack Post Office and Courthouse, 5 Post Office Square. Boston is the primary New England trial city, drawing petitioners from Maine, New Hampshire, Vermont, Rhode Island, and western Massachusetts. Petitions are filed at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

Massachusetts Department of Revenue

The state tax authority, at mass.gov/dor. Headquartered at 100 Cambridge Street, Suite 800, Boston MA 02114. Administers the flat 5% personal income tax under M.G.L. Ch 62 § 4(b), the 4% Millionaires Tax surcharge on income above $1 million under M.G.L. Ch 62 § 4(d), the 8% corporate excise tax under M.G.L. Ch 63 § 39, the 6.25% state sales-and-use tax under M.G.L. Ch 64H and Ch 64I, withholding tax, the room-occupancy excise on short-term rentals, the Massachusetts estate tax under M.G.L. Ch 65C, and the Offer in Final Settlement program under M.G.L. Ch 62C § 37A.

Massachusetts Appellate Tax Board

The state's specialized administrative tax tribunal, established 1930 under M.G.L. Ch 58A and the oldest dedicated state-tax tribunal in the United States. Seated at 100 Cambridge Street, 2nd Floor, Boston MA 02114. Hears disputes between taxpayers and the Massachusetts Department of Revenue, local boards of assessors, and other tax-administering agencies. 60-day petition deadline from a final DOR assessment under M.G.L. Ch 58A § 7. Decisions are appealable to the Massachusetts Appeals Court.

City of Boston Office of the Treasury and Collector-Treasurer

The municipal finance authority for the City of Boston. Office at 1 City Hall Square, Room 213, Boston MA 02201. Page: boston.gov/departments/treasury. Administers City of Boston property-tax collection, motor-vehicle excise, and municipal lien certificates. Note that Suffolk County has no separate county government for most administrative purposes — the City of Boston handles county functions through the Mayor's office. NFTLs affecting Boston-located property are recorded with the Suffolk County Registry of Deeds.

Boston Assessing Department

The City of Boston's property-assessment office, at 1 City Hall Square, Room 301, Boston MA 02201. Administers real-property assessments for the City of Boston, the residential exemption, the personal-exemption clauses (Clause 17, 18, 22, 37A, 41A), and the senior tax-deferral program. Property-tax assessment appeals run to the Massachusetts Appellate Tax Board under M.G.L. Ch 59 § 64.

U.S. District Court — District of Massachusetts, Boston 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. Mass., Boston Division), located at the John Joseph Moakley United States Courthouse, 1 Courthouse Way, Boston MA 02210, 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. Boston cases run through the Appeals offices serving the New England region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Taxpayer Advocate Service — Boston

An independent organization within the IRS that helps when normal channels stall. The Boston Local Taxpayer Advocate office serves taxpayers across Massachusetts and northern New England. Page: taxpayeradvocate.irs.gov.

Suffolk County Registry of Deeds

The recording office for Notices of Federal Tax Lien and Massachusetts state tax liens affecting real property in Boston, Chelsea, Revere, and Winthrop. Office at the Edward W. Brooke Courthouse, 24 New Chardon Street, Boston MA 02114. NFTL recording on the wrong county registry fails to attach to title — a procedural defect that can be the basis of a lien-withdrawal request under Form 12277.

Speak with a tax attorney about your Boston matter

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

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Frequently asked questions — Boston tax

What is the Massachusetts Millionaires Tax and when does it apply?

The Fair Share Amendment, codified at M.G.L. Ch 62 § 4(d), adds a 4% surcharge on Massachusetts taxable income above $1 million per filer. It was approved by Massachusetts voters in 2022 and took effect for tax year 2023. The $1 million threshold is not indexed automatically by statute (the Massachusetts DOR adjusts annually for inflation under a separate rule). The surcharge sits on top of the flat 5% Massachusetts personal income tax under M.G.L. Ch 62 § 4(b), producing a 9% combined Massachusetts rate on each dollar above $1 million. The threshold is calculated on the joint return total when filing jointly — one return, one threshold, no doubling for married couples. Equity-vest spike years, K-1 carry distributions, founder-stock §1202 exclusion events, and athletic playoff bonuses all push past the threshold in a single year.

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

The U.S. Tax Court holds regular trial sessions in Boston itself at the John W. McCormack Post Office and Courthouse, 5 Post Office Square. Boston is the primary New England trial city — a Maine, New Hampshire, Vermont, Rhode Island, or western Massachusetts petitioner can request the Boston 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 Massachusetts Appellate Tax Board and what is its deadline?

The Massachusetts Appellate Tax Board (ATB) is the state's specialized administrative tax tribunal, established in 1930 under M.G.L. Ch 58A and the oldest dedicated state-tax tribunal in the United States. It sits at 100 Cambridge Street, 2nd Floor, Boston MA 02114, and hears disputes between taxpayers and the Massachusetts Department of Revenue, local boards of assessors (property-tax appeals), and other tax-administering agencies. The petition deadline is 60 days from a final DOR assessment under M.G.L. Ch 58A § 7 — tighter than the federal 90-day Tax Court deadline but more generous than some states' 30-day windows. Decisions are appealable to the Massachusetts Appeals Court. Victory Tax Lawyers refers Appellate Tax Board litigation to locally admitted Massachusetts counsel; we handle the federal portion and the DOR administrative work directly.

Does Suffolk County have its own tax authority separate from the City of Boston?

No. Suffolk County in Massachusetts has no separate county government for most administrative purposes — an arrangement unique to a few Massachusetts counties that abolished county-level government in 1999. The City of Boston, through the Mayor's office and the Office of the Treasury and Collector-Treasurer at 1 City Hall Square Room 213, handles former Suffolk County functions for Boston residents. Chelsea, Revere, and Winthrop are the other Suffolk County municipalities and run their own collector and assessor offices. The Suffolk County Registry of Deeds at the Edward W. Brooke Courthouse, 24 New Chardon Street, remains the recording office for real-property documents including Notices of Federal Tax Lien.

What is Massachusetts' collection statute of limitations?

M.G.L. Ch 62C § 26 gives the DOR three years from a return's due date to assess Massachusetts income tax (extended to six years for substantial omissions of more than 25% of gross income, with no limit for fraud or unfiled returns). Once an assessment is final, the DOR's right to collect runs for six years from the assessment date under M.G.L. Ch 62C § 65, 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. Coordinated case planning hinges on knowing both clocks before any action that could restart either one.

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

Yes. The IRS and the Massachusetts Department of Revenue operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to Massachusetts under the state's federal-change reporting rule (M.G.L. Ch 62C § 30), and vice versa. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the Massachusetts return — particularly important given the 4% Millionaires Tax surcharge, which multiplies any federal adjustment that pushes you across the $1 million threshold by an extra 4% of state tax on that dollar.

Does Massachusetts have an Offer in Compromise equivalent to the federal program?

Yes. The Massachusetts Department of Revenue accepts Offers in Final Settlement under M.G.L. Ch 62C § 37A. The DOR 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 Massachusetts returns must be filed before consideration, current-year withholding and estimated-tax compliance is verified, and a financial-disclosure package is required. We typically run a state Offer in parallel with the federal Offer where both debts are real.

I work in Kendall Square biotech — how does §1202 Qualified Small Business Stock apply?

IRC § 1202 excludes from federal gross income up to the greater of $10 million or 10x basis on the sale of qualified small business stock held for more than five years from original issuance. The five-year clock starts on the date the stock is acquired from the corporation in exchange for cash, property, or services — not on a §83(b) election or vest date. Most Moderna, Biogen, Vertex, Sarepta, Bluebird, and earlier-stage Kendall Square biotech founders received stock that qualifies if the company had under $50 million in gross assets at issuance and engaged in a qualified active trade or business (biotech research clearly qualifies under the statute). Massachusetts conforms to IRC § 1202 in part but applies its own state-level exclusion calculation under M.G.L. Ch 62 § 2(a)(1). Documentation of the issuance date, original asset test, and basis is the single most valuable thing a biotech founder can keep on file.

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

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 Boston. For Massachusetts DOR administrative work, we file Form M-2848 Power of Attorney and handle the matter remotely. For formal litigation before the Massachusetts Appellate Tax Board or a Massachusetts Appeals Court proceeding, we co-counsel with locally admitted Massachusetts 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). Massachusetts follows a parallel filing-compliance posture under M.G.L. Ch 62C § 26; the DOR may assess based on federal-change reporting or estimate tax when a taxpayer fails to file.

Can the IRS levy my Boston 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 Eastern Bank, Citizens, Bank of America, Santander, Cambridge Trust, Rockland Trust, or any Massachusetts-chartered institution and serve wage levies on Boston employers including Mass General Brigham, Fidelity, State Street, Wellington, Harvard, MIT, and any Kendall Square biotech. 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). Massachusetts issues parallel state tax liens under M.G.L. Ch 62C § 50 recorded in the appropriate county Registry of Deeds.

I work at Fidelity, State Street, or Wellington 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% Massachusetts plus the 4% Millionaires Tax surcharge once your total taxable income clears $1 million, and a single year of vesting can produce a $50,000 to $300,000+ balance due. The fix is W-4 adjustment plus quarterly Form 1040-ES under IRC § 6654 and Massachusetts Form 1-ES under M.G.L. Ch 62B § 14.

A family member died in Massachusetts — do I owe state estate tax?

Possibly yes. The Massachusetts estate-tax exemption under M.G.L. Ch 65C is $2 million per estate — one of the lowest in the country and far below the $13.61 million federal exemption for 2024 returns. Massachusetts is one of seventeen states plus the District of Columbia that still imposes a state-level estate tax, with rates running up to 16% on the portion above the exemption. A Beacon Hill brownstone or Back Bay condo plus a Wellesley primary residence, a Cape Cod second home, retirement accounts, and life-insurance proceeds can cross the $2 million Massachusetts threshold without anyone realizing a state filing is required. Form M-706 is due nine months from death. Coordination with the federal Form 706 estate-tax return is its own engagement layer.

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 Massachusetts Offer in Final Settlement under M.G.L. Ch 62C § 37A 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. Massachusetts state collection follows a similar pattern: a Form M-2848 routes DOR contact, and a pending Massachusetts Offer in Final Settlement 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: May 25, 2026. Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Massachusetts statute citation references the Massachusetts General Laws. 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 Massachusetts Department of Revenue, the U.S. Tax Court, the Massachusetts Appellate Tax Board, 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 Commonwealth of Massachusetts; where a Massachusetts state-court appearance or Massachusetts Appellate Tax Board 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. § 1202 — Qualified Small Business Stock
26 U.S.C. § 1061 — Carried-Interest Holding Period
26 U.S.C. § 174 — R&D Capitalization
26 U.S.C. § 83 — Property Transferred for Services / 83(b) Election
26 U.S.C. § 280A — Short-term rental classification
M.G.L. Ch 62 § 4(b) — Massachusetts flat 5% personal income tax
M.G.L. Ch 62 § 4(d) — Massachusetts Fair Share Amendment / Millionaires Tax
M.G.L. Ch 63 § 39 — Massachusetts corporate excise tax
M.G.L. Ch 64H § 2 — Massachusetts sales tax
M.G.L. Ch 64I — Massachusetts use tax
M.G.L. Ch 65C — Massachusetts estate tax
M.G.L. Ch 58A § 7 — Appellate Tax Board petition deadline
M.G.L. Ch 62C § 26 — Massachusetts assessment statute of limitations
M.G.L. Ch 62C § 31A — Massachusetts responsible-person liability
M.G.L. Ch 62C § 33 — Massachusetts failure-to-file penalty
M.G.L. Ch 62C § 35A — Massachusetts accuracy-related penalty
M.G.L. Ch 62C § 37A — Massachusetts Offer in Final Settlement
M.G.L. Ch 62C § 50 — Massachusetts state tax lien
M.G.L. Ch 62C § 65 — Massachusetts collection statute