Tax Attorney in Buffalo, NY

Federal IRS representation for Western New York taxpayers and US-Canada cross-border filers — audits, back taxes, FBAR, IRC § 217 commuter elections, RRSP and TFSA reporting, liens, levies, and US Tax Court litigation at 2 Niagara Square. We coordinate New York State Department of Taxation and Finance matters via Form POA-1 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 Buffalo, Niagara Falls, Amherst, Tonawanda, Cheektowaga, Lackawanna, and Erie and Niagara counties

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

Buffalo sits at the busiest US-Canada land border in New York State. The Peace Bridge moves tens of thousands of commuters, tour operators, and dual-status workers between Buffalo and Fort Erie every day, and the Lewiston-Queenston Bridge adds a second crossing twenty miles north. That cross-border footprint makes Buffalo one of the most FBAR-exposed cities in the United States outside of New York City and Miami — RRSPs, TFSAs, Canadian bank accounts, and Ontario business interests all trigger FinCEN Form 114 filing under 31 U.S.C. § 5314 once aggregate balances cross $10,000, plus IRS Form 8938 reporting under IRC § 6038D on a separate threshold. The US-Canada Tax Convention — particularly Articles 14 (independent personal services), 15 (dependent personal services), and 17 (artistes and athletes) — sits on top of every dual-status filing.

On the state side, Buffalo is upstate New York and is therefore outside the New York City personal income tax and outside the NYC Unincorporated Business Tax under NYC Admin Code § 11-503. Buffalo residents pay federal income tax under IRC § 1, the New York State graduated personal income tax topping at 10.9% under NY Tax Law § 601, the 6.5% New York State corporate franchise tax (top bracket 7.25% on income above $5 million) under NY Tax Law § 210, the 4% state sales tax plus 4.75% Erie County local tax plus 0.25% Niagara Frontier Transportation Authority surcharge for a combined 8.75% Buffalo sales-tax rate under NY Tax Law § 1105, the New York State estate tax with its 2026-indexed exemption around $7.16 million and the notorious cliff rule under NY Tax Law § 952, and any City of Buffalo property tax administered by the Department of Assessment and Taxation at 65 Niagara Square.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the New York State Department of Taxation and Finance has issued a Notice of Determination from its Buffalo District Office at 65 Court Street, the deadlines run fast. We pull your IRS account transcripts, calculate your CSED under IRC § 6502, file Form 2848 Power of Attorney with the IRS, file Form POA-1 with the New York State Department of Taxation and Finance, and put administrative brakes on collection while the case is built.

Federal tax representation for Buffalo 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 Buffalo at the Robert H. Jackson United States Courthouse, 2 Niagara Square. From our Robertson Boulevard office in Los Angeles, we represent Buffalo residents, Western New York taxpayers, and entities domiciled across Erie and Niagara counties 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, Trust Fund Recovery Penalty defenses under IRC § 6672, FBAR and FATCA disclosure work under 31 U.S.C. § 5314 and IRC § 6038D, Streamlined Filing Compliance submissions, and US-Canada Tax Convention treaty positions.

For New York State tax matters — the graduated 4% to 10.9% personal income tax under NY Tax Law § 601, the 6.5% (top 7.25%) corporate franchise tax under NY Tax Law § 210, the New York State estate tax with its $7.16 million 2026-indexed exemption and cliff rule under NY Tax Law § 952, the 4% state sales tax under NY Tax Law § 1105 with the 4.75% Erie County add-on, and contested matters headed to the New York State Division of Tax Appeals or the New York State Tax Appeals Tribunal — we file Form POA-1 with the Department of Taxation and Finance and handle the administrative track directly. Buffalo taxpayers are outside the New York City personal income tax and outside the NYC Unincorporated Business Tax; that two-layer NYC stack does not apply upstate, which materially reduces the multi-tax exposure compared with a Manhattan resident. For formal litigation before the New York State Tax Appeals Tribunal (the independent state-tax tribunal seated at Agency Building 1, 6th Floor, in Albany under NY Tax Law § 170 et seq.) or in the New York Supreme Court Tax Term sitting in Erie County, we refer to locally admitted New York counsel under a co-counsel arrangement. The federal layer — where most cross-border FBAR, Streamlined Filing, US-Canada treaty, and Tax Court matters live — stays with us.

Buffalo carries an unusual federal-tax footprint for a city of its size. The US-Canada border at the Peace Bridge produces a steady book of dual-status, treaty-resident, and cross-border-commuter cases — Buffalo residents who work in Fort Erie or Niagara Falls, Ontario; Ontario residents who work in Buffalo or Niagara Falls, NY; tour operators running Schedule C activities on both sides of the Niagara River; short-term rental hosts on the American side capturing Canadian tourism under IRC § 280A. The headquarters cluster on the American side of the border includes M&T Bank Corporation at One M&T Plaza (Buffalo's largest private employer, parent of Wilmington Trust since the 2011 acquisition), Delaware North at 250 Delaware Avenue (food-service, concession, and the Boston Bruins ownership), the Buffalo Bills at Highmark Stadium in Orchard Park, the Buffalo Sabres at KeyBank Center, the legacy HSBC operations now under KeyBank ownership, Rich Products on Niagara Street, Tops Friendly Markets, and the General Motors Tonawanda Engine Plant in Buffalo's northern industrial corridor. Add the academic and research cluster — University at Buffalo (UB-SUNY), Canisius University, Niagara University, Buffalo State, D'Youville University — plus the medical complex anchored by Roswell Park Comprehensive Cancer Center (NCI-designated since 1898, the oldest cancer center in the United States), Buffalo General Medical Center, Erie County Medical Center, Catholic Health, and Kaleida Health, plus the MOOG Inc. aerospace-defense headquarters in East Aurora, and you have a tax-resolution footprint that is unusually heavy on cross-border FBAR, IRC § 174 R&D capitalization, IRC § 1202 Qualified Small Business Stock, clinical-trial royalty work, banking RSU and ISO compensation, professional-athlete NY-source sourcing under NY Tax Law § 631, and FBAR work on Polish, Italian, African-American, Yemeni, Iraqi, Burmese Karen, and other immigrant and refugee communities resettled through the International Institute of Buffalo.

Your tax rights as a Buffalo taxpayer

Two parallel rights frameworks apply when you owe tax in Buffalo. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from the New York Tax Law, the Department of Taxation and Finance's published Taxpayer Bill of Rights under NY Tax Law § 3000, and the procedural rules of the New York State Division of Tax Appeals and Tax Appeals Tribunal. Knowing both is the difference between a clean resolution and a missed 90-day Tribunal petition window that locks in a state assessment against your Allentown loft, your Elmwood Village home, or your Williamsville business.

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. New York State mirrors this through Form POA-1 accepted by the Department of Taxation and Finance and processed by the Buffalo District Office at 65 Court Street.

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 Buffalo at the Robert H. Jackson United States Courthouse, 2 Niagara Square — serving Western New York petitioners from Erie, Niagara, Cattaraugus, Chautauqua, Allegany, Genesee, Orleans, and Wyoming counties.

Right to Tax Appeals Tribunal review

NY Tax Law § 2010 gives you 90 days from a final Department of Taxation and Finance Notice of Determination to file a petition with the New York State Division of Tax Appeals, an independent body whose decisions are reviewed by the New York State Tax Appeals Tribunal at Agency Building 1, 6th Floor, W A Harriman State Campus, Albany. Missing the 90-day window forfeits the right to pre-payment review of the state assessment. Tribunal litigation is referred to locally admitted New York counsel; we handle the administrative track and the federal portion directly.

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 with the Erie County Clerk 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. New York State runs a parallel Offer in Compromise program under NY Tax Law § 171.fifteenth administered by the Department of Taxation and Finance, with similar hardship and insolvency standards. Each program requires 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 — particularly in audit reconsideration cases and Innocent Spouse cases under IRC § 6015.

How Victory Tax Lawyers helps Buffalo 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 Buffalo taxpayers carrying parallel state liabilities, we run a separate New York State Offer in Compromise filing with the Department of Taxation and Finance under NY Tax Law § 171.fifteenth on the same financial showing — coordinating each program so an accepted federal Offer does not break a pending state offer. Cross-border RRSP and TFSA balances are surfaced and characterized correctly on the Form 433 financial disclosure rather than buried.

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 Buffalo taxpayers carrying between $50,000 and $250,000 in federal debt, including M&T Bank, Delaware North, Roswell Park, and University at Buffalo employees whose RSU vests or supplemental compensation produced an underwithholding surprise. New York State runs a separate twenty-year collection clock under NY Tax Law § 174-b — double the federal CSED — which materially changes the partial-pay arithmetic on the state side.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Buffalo property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Erie County Clerk's Office at 92 Franklin Street encumber title on Allentown, Elmwood Village, North Buffalo, South Buffalo, West Side, Black Rock, Riverside, Kenmore, Tonawanda, Williamsville, Amherst, Cheektowaga, Hamburg, Orchard Park, and Lackawanna real estate. New York State tax warrants are docketed in the Erie County Clerk's office under NY Civil Practice Law and Rules § 5018 and operate as judgment liens against real and personal property. 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. New York State tax warrants are enforced through Erie County Sheriff levies and income executions under NY Tax Law § 174 and the New York CPLR.

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), Canadian RRSP and TFSA treatment under the US-Canada Tax Convention, US-Canada commuter and treaty-residency positions under IRC § 217 and Convention Articles 14, 15, and 17, S-corporation reasonable-compensation, § 83(b) election validity for biotech and aerospace startup grants, IRC § 174 R&D capitalization at Roswell Park, MOOG, and University at Buffalo research programs, IRC § 1202 Qualified Small Business Stock claims on Buffalo Niagara Medical Campus biotech exits, and NY State residency disputes for taxpayers who relocated to Florida or moved cross-border to Ontario. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Buffalo trial sessions are held at the Robert H. Jackson United States Courthouse, 2 Niagara Square.

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. FBAR willfulness penalties under 31 U.S.C. § 5321 — capped at the greater of $129,210 (2024-indexed) or 50% of the account balance per year — are defended through a non-willful position under the Streamlined Filing Compliance Procedures, where the cumulative cost is materially lower. New York State penalties under NY Tax Law § 685 (failure to file) and § 685(p) (substantial understatement) follow a separate reasonable-cause analysis applied by the Department of Taxation and Finance and reviewable by the Division of Tax Appeals.

Twelve types of Buffalo tax matters we handle

Federal cases for Western New York taxpayers, framed against the NYS DTF overlay where it matters.

US-Canada cross-border FBAR and Form 8938

Buffalo residents with Canadian bank accounts, RRSPs, TFSAs, RESPs, Canadian brokerage accounts, or Ontario business interests trigger FinCEN Form 114 reporting under 31 U.S.C. § 5314 once aggregate balances cross $10,000, plus IRS Form 8938 reporting under IRC § 6038D on a separate threshold ($50,000 / $100,000 single, $100,000 / $150,000 joint year-end and high-water). The Streamlined Filing Compliance Procedures cure non-willful past failures — the most common Buffalo cross-border engagement we handle.

Peace Bridge commuter and IRC § 217

Buffalo residents who work in Fort Erie, Niagara Falls Ontario, or Toronto, and Canadian residents who work in Buffalo or Niagara Falls NY, face a dual-status return cycle. IRC § 217 governs moving-expense deductions; the US-Canada Tax Convention Articles 14 (independent personal services), 15 (dependent personal services), and 17 (artistes and athletes) allocate taxing rights and prevent double taxation through the Article XXIV foreign-tax-credit mechanism. Treaty positions are taken on Form 8833.

Niagara Falls tour operator and STR

Niagara Falls draws roughly 14 million visitors a year. Schedule C tour operators, Airbnb and Vrbo hosts on the American side, and bed-and-breakfast owners face a stack of issues: IRC § 280A vacation-rental classification, the 14-day Augusta rule, IRC § 469 passive-activity loss limits, the Maine-Tax-Court-leaning short-term-rental personal-services characterization, and New York State sales tax on lodging at 4% state plus county add-on under NY Tax Law § 1105(e). The cross-border tourism revenue brings 1099-K reporting from Stripe, Square, and the platforms.

M&T Bank and Delaware North RSU / ISO

M&T Bank Corporation (Buffalo's largest private employer, parent of Wilmington Trust since 2011), Delaware North (food-service, concession, and Boston Bruins ownership at 250 Delaware Avenue), KeyBank (post-2011 absorbing the legacy HSBC USA Buffalo operations), and Citizens Bank Western New York employees hold RSU and ISO grants. ISO disqualifying dispositions trigger AMT under IRC § 55; § 83(b) elections demand exact 30-day windows; supplemental wage withholding of 22% federal sits below the actual marginal rate. The shortfall plus the 10.9% NY State top bracket produces a balance due the following April.

Roswell Park biotech and clinical-trial royalty

Roswell Park Comprehensive Cancer Center (NCI-designated since 1898 — the oldest cancer center in the United States) generates a steady volume of NIH-grant-funded research, Cooperative Research and Development Agreements with industry, clinical-trial royalties from CAR-T and immunotherapy IP, and IRC § 174 R&D capitalization complications introduced by the 2017 TCJA. Researcher-physicians carry 1099 royalty income, partnership equity in Buffalo Niagara Medical Campus biotech spinouts, and IRC § 1202 Qualified Small Business Stock exposure on five-year-held founder stock.

MOOG Inc. aerospace and IRC § 174 R&D

MOOG Inc., headquartered in East Aurora about 30 miles south of downtown Buffalo, designs flight-control and motion-control systems for aerospace and defense applications. The 2017 TCJA amendment of IRC § 174 requires capitalization and 5-year amortization of domestic research-and-experimental expenditures (15-year for foreign), reversing the immediate-deduction rule that aerospace and defense contractors had relied on since 1954. The cash-tax impact on MOOG suppliers and engineers with side consulting income is real and ongoing.

Buffalo Bills and Sabres pro-athlete NY-source income

NY Tax Law § 631 sources income earned by nonresident professional athletes to New York based on duty days. A Buffalo Bills or Buffalo Sabres player who maintains residency in Florida, Texas, Nevada, or Tennessee still pays New York State tax on the New York-duty-day portion of salary, signing bonus, and performance bonus. NY's 10.9% top rate is the relevant ceiling. Visiting opponents' New York-duty-day income runs through the same allocation. K-1 distributions from team-owner partnerships add another layer.

University at Buffalo academic and clergy

UB-SUNY, Canisius University, Niagara University, Buffalo State, and D'Youville University faculty, post-docs, graduate students, clergy, and chaplains carry their own tax footprint. IRC § 117(c) on post-doctoral stipends with required services, IRC § 107 parsonage allowance for clergy, IRC § 174 capitalization for sponsored research, IRC § 61 NIL income for UB Bulls athletes, and IRC § 911 foreign earned-income exclusion for international visiting scholars all appear regularly. Form 1042-S withholding for visiting researchers funded by foreign governments runs through IRC § 1441 nonresident-alien withholding.

GM Tonawanda Engine UAW manufacturing

The General Motors Tonawanda Engine Plant, on the northern edge of Buffalo's industrial corridor, employs a UAW workforce with overtime, profit-sharing, RSU components, and tier-two wage structures that create their own underwithholding patterns. The Ford Stamping Plant in Hamburg, Tesla's Gigafactory NY at the former RiverBend, and Sumitomo Rubber's Tonawanda operations add to the manufacturing tax footprint. CP14 notices and CP2000 reconciliations on multi-employer pension distributions appear regularly.

Refugee and immigrant FBAR — Yemen, Iraq, Karen, Polish, Italian

Buffalo is one of the larger US refugee resettlement cities, served primarily by the International Institute of Buffalo, Jericho Road Community Health Center, Catholic Charities, and Jewish Family Services. Yemeni-American (Lackawanna), Iraqi-American (West Side), Karen Burmese (West Side), Somali, Bhutanese, Polish-American (Black Rock and Cheektowaga), Italian-American (West Side and South Buffalo), and African-American families routinely hold overseas accounts that trigger FBAR reporting under 31 U.S.C. § 5314. The Streamlined Filing Compliance Procedures cure non-willful past failures.

Lake-effect snow disaster losses

Buffalo's lake-effect snow events — including the November 2014 Snowvember storm, the December 2022 blizzard, and recurring South Buffalo and South Towns whiteouts — produce property-loss claims. IRC § 165(h) allows a casualty-loss deduction only when the loss is attributable to a federally declared disaster under the post-2017 TCJA limitation. The disaster declaration date controls; reasonable cause for late-filed returns under IRM 20.1.1 frequently leans on the declaration timeline.

Cryptocurrency, royalty, and 1099 reporting

CP2000 notices on unreported digital-asset gains, basis-tracking failures, and DeFi-protocol income. Form 1099-DA reporting (effective 2025) drives the matching cases. Buffalo's musician, artist, and freelance-creative community generates 1099-NEC and royalty income across the Allentown, Elmwood Village, and Larkinville corridors. New York treats royalty income as ordinary income subject to the 4%-10.9% graduated state rate.

Nine common causes of tax debt for Buffalo taxpayers

Patterns we see repeatedly in Western New York engagements. None of them are unusual — all of them are resolvable.

1. Cross-border income reported only on the Canadian side

A Buffalo resident working in Fort Erie or Niagara Falls Ontario files a Canadian T1 and assumes the US obligation is satisfied. It is not. US citizens and residents are taxed on worldwide income under IRC § 1; the US-Canada Tax Convention's Article XXIV foreign-tax-credit mechanism prevents double taxation but does not relieve the US filing obligation. Missing Form 1040 and FBAR filings produces a multi-year cure through Streamlined Filing.

2. RSU and ISO underwithholding

An M&T Bank, Delaware North, KeyBank, or BlueCross BlueShield of Western New York employee at the 32% or 35% federal bracket sees only 22% supplemental withholding on RSU vests and bonuses. The shortfall, plus 6.85% to 10.9% NYS at the applicable bracket, produces a five- or six-figure balance due the following April.

3. Self-employment without estimated tax

Buffalo Niagara Medical Campus 1099 physicians, Allentown gallery artists, Elmwood Village freelance creatives, Larkinville consultants, and Niagara Falls tour operators file Schedule C income with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654.

4. Business closure

When an LLC, S-corp, or early-stage Buffalo startup closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Common in the Buffalo restaurant cycle (Elmwood, Hertel, Allentown) and the Buffalo Niagara Medical Campus biotech-failure pattern.

5. 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 dual-income Buffalo households where one spouse's K-1 carry, partner draw, or cross-border consulting income surprised the other.

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. New York treats digital-asset gains as taxable income at the full state graduated rate.

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. New York mirrors the federal three-year refund bar under NY Tax Law § 687. Lake-effect-storm disaster declarations can extend filing deadlines under IRC § 7508A — track each declaration carefully.

8. Real-estate sale without estimated tax

A Buffalo home, Tonawanda multi-family, Hamburg or Orchard Park single-family, or Niagara County waterfront sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Investor flips are 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 M&T, Delaware North, MOOG, and Buffalo Niagara Medical Campus biotech 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 — particularly costly for founders whose early-grant basis was low and whose § 1202 QSBS holding period depends on a valid election.

Eight tax liabilities that pull in Buffalo taxpayers

Federal authority alongside the New York State parallels.

Failure to file federal return

IRC § 6651(a)(1) imposes 5% per month, capped at 25%, plus interest under IRC § 6601. The New York mirror is NY Tax Law § 685(a)(1) imposing 5% per month, capped at 25%, on unpaid New York State personal income tax.

Failure to file New York State return

NY Tax Law § 685(a) imposes a 5% per month penalty on unpaid New York tax for failure to file, capped at 25%, plus interest under NY Tax Law § 684. The Department of Taxation and Finance may issue a Notice of Determination triggering the 90-day Tax Appeals Tribunal petition window under NY Tax Law § 2010. Statutory residence under NY Tax Law § 605 captures taxpayers who maintain a permanent place of abode in New York and spend more than 183 days in the state.

FBAR willfulness and Form 8938

31 U.S.C. § 5321(a)(5) imposes a willfulness penalty up to the greater of $129,210 (2024-indexed) or 50% of the account balance per year, per account. Non-willful penalties run up to $16,117 per violation. IRC § 6038D adds the Form 8938 reporting regime with a $10,000 failure-to-file penalty plus 40% accuracy-related penalty on tax attributable to undisclosed assets under IRC § 6662(j). The Streamlined Filing Compliance Procedures cap the penalty at 5% (domestic) or 0% (foreign) of the high-water balance.

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. RRSP and TFSA balances are disclosed and characterized under Form 433-A(OIC) Section 5.

New York sales-tax delinquency

The combined Buffalo sales-tax rate is 8.75%: 4% New York State (NY Tax Law § 1105), 4.75% Erie County local, and 0.25% Niagara Frontier Transportation Authority surcharge. NY Tax Law § 685(g) imposes personal liability on responsible persons for unpaid trust-fund sales tax — one of the most aggressively enforced state-tax regimes in the country. Use-tax assessments under NY Tax Law § 1110 target businesses purchasing equipment from out of state or from Ontario without paying use tax on the bring-in.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. New York applies parallel responsible-person rules to withheld state income tax under NY Tax Law § 685(g). Buffalo restaurant, construction, hospitality, and Buffalo Niagara Medical Campus startup owners are common targets.

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. NY Tax Law § 685(p) imposes a parallel 10% to 20% New York accuracy-related penalty on substantial understatements.

New York State estate tax with cliff

NY Tax Law § 952 imposes the New York estate tax on estates above the 2026-indexed exemption of approximately $7.16 million, with a graduated rate scale topping out at 16%. The cliff rule applies: estates valued at more than 105% of the exemption lose the credit entirely and pay state estate tax from the first dollar — a feature unique to New York among estate-tax states. A Buffalo home, a Chautauqua or Lake Erie summer place, retirement accounts, and life-insurance proceeds can cross the cliff threshold without anyone realizing. Form ET-706 is due nine months from death.

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 IRS 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 Erie County Clerk.

Sample tax-resolution outcomes

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

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

Past results do not guarantee future outcomes. Each tax case is unique. Results depend on the specific facts of the matter, including the taxpayer's financial condition, compliance history, and the discretion of the Internal Revenue Service and the New York State Department of Taxation and Finance.

Why Victory Tax Lawyers for a Buffalo federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not New York-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 Buffalo at the Robert H. Jackson United States Courthouse, 2 Niagara 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 Buffalo clients never need a separately admitted New York attorney because the case is, at its core, federal — particularly the cross-border FBAR and Streamlined Filing matters that dominate the Buffalo and Niagara County book.

For administrative work before the New York State Department of Taxation and Finance — protests filed at the Buffalo District Office at 65 Court Street Suite 6, audit responses, Offer in Compromise submissions under NY Tax Law § 171.fifteenth, and installment-agreement requests — we file Form POA-1 and handle the matter remotely. When a case must move to the New York State Division of Tax Appeals or the New York State Tax Appeals Tribunal (the independent state-tax tribunal seated at Agency Building 1, 6th Floor, in Albany under NY Tax Law § 170 et seq.) or appeal further to the Appellate Division, Fourth Department (which sits in Rochester and reviews Western New York state appeals), we coordinate with locally admitted New York counsel under a co-counsel arrangement. The federal portion of the engagement — usually the larger exposure on a cross-border or biotech-RSU case — 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 New York-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Buffalo 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 Buffalo 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 POA-1

We file the federal Power of Attorney with the IRS and Form POA-1 with the New York State Department of Taxation and Finance, then step in as the contact of record on each agency.

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events. The parallel twenty-year NYS collection clock under NY Tax Law § 174-b is mapped on the same chart.

Strategy memo

A written summary: the resolution path (OIC, IA, CNC, audit response, CDP, Tax Court, Streamlined Filing), 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, a Streamlined Filing certification, or a NYS DTA petition through local counsel — and handle every IRS and NYS contact.

Compliance monitoring

After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, including continuing FBAR and Form 8938 filings, and prevent default.

Two collection clocks: federal CSED and New York's twenty-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 — a tolling rule that matters for Buffalo residents who relocate to Toronto, Hamilton, or anywhere in Ontario for an extended cross-border employment stint.

New York State runs a markedly longer collection rule under NY Tax Law § 174-b: the Department of Taxation and Finance generally has twenty years from the date of the docketed tax warrant to collect, with renewal possible. That is double the federal CSED and one of the longest collection statutes in the country. Many Buffalo taxpayers carry a federal CSED that will run out a decade before the New York State warrant clock expires. Pull both records and know both timelines before agreeing to any payment plan or amended return that could restart a clock.

Buffalo tax authorities and venues

A working knowledge of the tribunals, agencies, and field offices in Buffalo is what separates an answered Notice from a wage levy or a docketed tax warrant. Below is the working list our firm uses on every Western New York matter.

Internal Revenue Service — Buffalo Taxpayer Assistance Center

The federal tax authority, at irs.gov. The Buffalo Taxpayer Assistance Center operates at 130 S Elmwood Avenue, Suite 100, Buffalo NY 14202 — appointments required. The TAC serves walk-in support for Buffalo, Niagara Falls, Lockport, Tonawanda, Cheektowaga, Amherst, Williamsville, Hamburg, Lackawanna, and the surrounding Western New York counties.

U.S. Tax Court — Buffalo trial sessions

The U.S. Tax Court holds regular trial sessions in Buffalo at the Robert H. Jackson United States Courthouse, 2 Niagara Square, Buffalo NY 14202. The Jackson Courthouse serves Western New York petitioners from Erie, Niagara, Cattaraugus, Chautauqua, Allegany, Genesee, Orleans, and Wyoming counties. Petitions are filed at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

New York State Department of Taxation and Finance

The state tax authority, at tax.ny.gov. Headquartered at the W A Harriman State Campus, Albany NY 12227, with a Buffalo District Office at 65 Court Street, Suite 6, Buffalo NY 14202. Administers the graduated 4%-10.9% personal income tax under NY Tax Law § 601, the 6.5%-7.25% corporate franchise tax under NY Tax Law § 210, the 4% state sales-and-use tax under NY Tax Law § 1105, withholding tax, the New York State estate tax under NY Tax Law § 952, and the Offer in Compromise program under NY Tax Law § 171.fifteenth.

New York State Tax Appeals Tribunal

The independent state-tax tribunal under NY Tax Law § 170 et seq., seated at Agency Building 1, 6th Floor, W A Harriman State Campus, Albany NY 12223. Reviews determinations of the New York State Division of Tax Appeals. Hears disputes between taxpayers and the New York State Department of Taxation and Finance covering personal income, corporate franchise, sales, estate, and related state taxes. The 90-day petition deadline runs from a final Notice of Determination under NY Tax Law § 2010. Tribunal decisions are appealable to the Appellate Division, Third Department; further appeals can run to the Appellate Division, Fourth Department in Rochester, which reviews Western New York state-court matters.

Erie County Comptroller

The fiscal officer of Erie County, at 95 Franklin Street, Buffalo NY 14202. Administers county receipts and disbursements. The Erie County Department of Real Property Tax Services operates from the same building at 95 Franklin Street, 1st Floor, and administers property-tax assessment review and tax sales for Erie County properties outside the City of Buffalo.

City of Buffalo Department of Assessment & Taxation

The municipal assessor for the City of Buffalo, at 65 Niagara Square, Room 101, Buffalo NY 14202. Administers city real-property assessments and the small-claims assessment review process under New York Real Property Tax Law § 730. Buffalo property-tax bills are issued and collected through the city; school-tax bills are billed by the Buffalo Public School District through the city.

U.S. District Court — Western District of New York, Buffalo 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 Western District of New York, with the Buffalo Division sitting at the Robert H. Jackson United States Courthouse, 2 Niagara Square, and at 68 Court Street, Buffalo NY 14202. The WDNY also sits in Rochester. Alternative venue: 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. Buffalo cases run through the Appeals offices serving Western New York. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Taxpayer Advocate Service — Buffalo

An independent organization within the IRS that helps when normal channels stall. The Buffalo Local Taxpayer Advocate Office serves taxpayers across Western New York. Page: taxpayeradvocate.irs.gov.

Erie County Clerk

The recording office for Notices of Federal Tax Lien and New York State tax warrants affecting real property in Erie County, at 92 Franklin Street, Buffalo NY 14202. The Niagara County Clerk in Lockport handles recordings for Niagara County properties (Niagara Falls, North Tonawanda, Lewiston, Youngstown, and the rural northern townships).

Speak with a tax attorney about your Buffalo matter

Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, a NYS Notice of Determination from the Buffalo District Office, or an FBAR or Form 8938 letter is in front of you, the deadline to respond is real and short — call today.

Call (800) 883-8301 Free Consultation

Frequently asked questions — Buffalo tax

I commute across the Peace Bridge to work in Ontario — how do I file?

A US citizen or US resident who works in Canada is taxed on worldwide income under IRC § 1, regardless of where the work is performed. Canadian-source employment income is reported on Form 1040, with Canadian tax credited back to the United States through the foreign tax credit under IRC § 901 and the US-Canada Tax Convention Article XXIV. Article 15 of the Convention (dependent personal services) generally assigns primary taxing rights to the country where the work is physically performed, with the residence country retaining a residual claim. We file Form 8833 to disclose the treaty position. Canadian RRSP, TFSA, and Canadian bank accounts trigger FBAR (FinCEN Form 114) and possibly Form 8938 reporting; we run that compliance work in parallel.

I have an RRSP from my time working in Toronto — do I owe US tax on the growth?

The US-Canada Tax Convention Article XVIII(7), and the related Rev. Proc. 2014-55, allow US taxpayers to defer current US taxation on RRSP growth until distribution — matching the Canadian deferral. No election filing is required for the deferral after Rev. Proc. 2014-55; older returns may have filed Form 8891. TFSA accounts do not receive the same treaty treatment and may be considered foreign grantor trusts requiring Form 3520 and Form 3520-A — a heavy compliance burden that traps many Buffalo cross-border filers. RRSPs and TFSAs are reported on FBAR (FinCEN Form 114) under 31 U.S.C. § 5314 once aggregate foreign account balances cross $10,000, and on Form 8938 under IRC § 6038D on a separate threshold.

I have unreported Canadian accounts going back several years — what are my options?

The IRS Streamlined Filing Compliance Procedures are the standard cure for non-willful past failures. For Buffalo residents (US domestic taxpayers), the Streamlined Domestic Offshore Procedures impose a 5% miscellaneous offshore penalty on the high-water aggregate value of the undisclosed foreign assets, plus the cost of three years of amended Form 1040 returns and six years of FBAR filings. For US citizens who lived in Canada and meet the non-residency tests, the Streamlined Foreign Offshore Procedures impose 0% penalty. Both programs require a non-willful certification. The IRS has shut down the older Offshore Voluntary Disclosure Program; the current OVDP variant (Voluntary Disclosure Practice under IRM 9.5.11.9) handles willful cases and carries a 75% civil fraud penalty.

What is the New York State top tax rate, and does Buffalo charge its own city income tax?

The New York State graduated personal income tax under NY Tax Law § 601 tops out at 10.9% on taxable income above $25 million for the 2026 tax year. Unlike New York City — which imposes its own NYC personal income tax of 3.078% to 3.876% under NYC Administrative Code § 11-1701 and a 4% Unincorporated Business Tax under NYC Admin Code § 11-503 — the City of Buffalo does not impose a city personal income tax. The NYC stack does not apply to upstate residents. Buffalo property tax is administered by the City of Buffalo Department of Assessment & Taxation at 65 Niagara Square; school tax is billed alongside it.

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

The U.S. Tax Court holds regular trial sessions in Buffalo itself at the Robert H. Jackson United States Courthouse, 2 Niagara Square. Buffalo is the designated Western New York trial city — petitioners from Erie, Niagara, Cattaraugus, Chautauqua, Allegany, Genesee, Orleans, and Wyoming counties request the Buffalo trial location when filing. 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 New York's collection statute of limitations?

New York State runs a markedly longer collection statute than the federal CSED. Under NY Tax Law § 174-b, the New York State Department of Taxation and Finance generally has twenty years from the date of the docketed tax warrant to collect, with renewal possible on continuing nonpayment. That is double the federal IRC § 6502 ten-year CSED and one of the longest state collection statutes in the country. Coordinated case planning hinges on knowing both timelines before any action that could restart a clock — an installment agreement request, an Offer submission, or an amended return can each toll one or both clocks.

I moved from Buffalo to Florida — do I still owe New York income tax?

Possibly yes. New York State taxes nonresidents on income sourced to New York under NY Tax Law § 631, and the “convenience of the employer” rule treats days worked from your Florida home as New York-source income when the work was performed for the convenience of the employee rather than the necessity of the employer. New York employers that maintain a New York office generally do not satisfy the necessity exception. Statutory residence under NY Tax Law § 605 also applies if you maintain a permanent place of abode in New York and spend more than 183 days in the state during the year — keeping a Buffalo home plus regular family-visit travel can pull a Florida-domiciled taxpayer back into full New York residency for the year. New York audits relocated high-income taxpayers aggressively. We address NYS residency exposure on the federal track.

Can I be audited by the IRS and the NYS DTF for the same year?

Yes. The IRS and the New York State Department of Taxation and Finance operate independently and share information through the IRS-state exchange program and through NY Tax Law § 211 federal-change reporting. A federal audit adjustment is routinely reported to New York; an NYS audit can trigger a federal review. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the state return.

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

Yes. The New York State Department of Taxation and Finance accepts Offers in Compromise under NY Tax Law § 171.fifteenth. The Department considers offers based on doubt as to collectibility, doubt as to liability, and undue economic hardship — standards that parallel federal IRC § 7122 analysis but with state-specific procedural rules and a separate disclosure package. All New York 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'm a Roswell Park researcher with clinical-trial royalty income — how is it taxed?

Royalty income from a federally funded clinical-trial assignment is generally ordinary income under IRC § 61 and subject to self-employment tax under IRC § 1401 to the extent the inventor receives a continuing royalty stream tied to ongoing services. The IRC § 174 capitalization regime introduced by the 2017 TCJA changed the timing of research-expense deductions for the institution, but does not directly affect royalty recipients. For founder stock in a Roswell Park or Buffalo Niagara Medical Campus biotech spinout, IRC § 1202 Qualified Small Business Stock can produce up to 100% gain exclusion on a five-year hold. Documentation of the original-issuance, active-business, and gross-asset tests is critical and must be built at acquisition, not at exit.

I work for M&T Bank or Delaware North — how does RSU underwithholding work?

M&T Bank and Delaware North RSUs are taxed as ordinary compensation under IRC § 83 when the shares vest, valued at the closing price on the vest date. Federal supplemental wage withholding under Treasury Reg. § 31.3402(g)-1 is 22% on the first $1 million of supplemental wages each year and 37% above that — well below the 32% / 35% / 37% marginal rates that an M&T senior vice president or Delaware North senior director faces. Stack the 6.85% to 10.9% NY State personal income tax on top, and the typical RSU vest produces a five- or six-figure shortfall the following April. The fix is quarterly estimated payments under IRC § 6654 (federal) and NY Tax Law § 685(c) (state), or supplemental withholding via a Form W-4 adjustment.

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

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 Buffalo. For New York State Department of Taxation and Finance administrative work, we file Form POA-1 and handle the matter remotely. For formal litigation before the New York State Tax Appeals Tribunal or a New York Supreme Court Tax Term proceeding, we co-counsel with locally admitted New York attorneys. Most engagements — audit defense, OIC, IA, levy release, Tax Court, FBAR, and Streamlined Filing — 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). New York follows a parallel filing-compliance posture under NY Tax Law § 683; the Department may assess based on federal-change reporting under NY Tax Law § 211 or estimate tax when a taxpayer fails to file.

Can the IRS levy my Buffalo bank account or wages?

Yes — after a Final Notice of Intent to Levy (CP90 or LT11) and expiration of the 30-day Collection Due Process window under IRC § 6330, the IRS may levy bank accounts at M&T Bank, KeyBank, Bank of America, Citizens Bank, Northwest Bank, Five Star Bank, Evans Bank, or any Buffalo-area financial institution and serve wage levies on Buffalo employers including M&T, Delaware North, Roswell Park, Buffalo General, Erie County Medical Center, Catholic Health, Kaleida Health, University at Buffalo, the City of Buffalo, Erie County, and MOOG. 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). New York State tax warrants are enforced through Erie County Sheriff levies and income executions under NY Tax Law § 174 and the New York CPLR.

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

Possibly yes, and the New York cliff rule may multiply the bill. NY Tax Law § 952 imposes the New York estate tax on estates above the 2026-indexed exemption of approximately $7.16 million per decedent, with a graduated rate scale topping out at 16%. The cliff rule under NY Tax Law § 952(c)(2): if an estate is valued at more than 105% of the exemption, the credit is lost entirely and state estate tax is owed from the first dollar — not just on the excess. A Buffalo home, a Lake Erie or Chautauqua summer place, retirement accounts, and life-insurance proceeds can cross the 105% threshold and forfeit the full credit without anyone realizing. Form ET-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 New York State Offer in Compromise under NY Tax Law § 171.fifteenth typically runs six to twelve 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 New York statute citation references the New York Tax Law. 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 New York State Department of Taxation and Finance, the U.S. Tax Court, the New York State Tax Appeals Tribunal, 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 New York; where a New York state-court appearance or New York State Tax Appeals Tribunal 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. § 6038D — Foreign Financial Asset Reporting (Form 8938)
26 U.S.C. § 217 — Moving Expenses
26 U.S.C. § 280A — Dwelling Unit Used Personally
26 U.S.C. § 174 — Research and Experimental Expenditures
26 U.S.C. § 1202 — Qualified Small Business Stock
26 U.S.C. § 165 — Casualty Losses
26 U.S.C. § 83 — Property Transferred for Services / 83(b) Election
31 U.S.C. § 5314 — FBAR (Foreign Bank Account Reporting)
NY Tax Law § 601 — New York State graduated personal income tax (4%-10.9%)
NY Tax Law § 605 — New York statutory residence (183-day rule)
NY Tax Law § 631 — New York nonresident sourcing
NY Tax Law § 210 — New York corporate franchise tax
NY Tax Law § 952 — New York State estate tax (cliff rule)
NY Tax Law § 1105 — New York State sales tax
NY Tax Law § 170 et seq. — New York State Tax Appeals Tribunal
NY Tax Law § 171.fifteenth — New York Offer in Compromise
NY Tax Law § 174 — New York State tax warrants
NY Tax Law § 174-b — New York twenty-year collection statute
NY Tax Law § 211 — New York federal-change reporting
NY Tax Law § 685 — New York additions to tax and penalties
NY Tax Law § 2010 — New York Tax Appeals Tribunal petition deadline
US-Canada Tax Convention, Articles 14, 15, 17, XVIII, XXIV — cross-border allocation and double-tax relief