Tax Attorney in Florida
Federal IRS resolution for Florida taxpayers. We handle Offers in Compromise, installment agreements, audit defense, lien and levy releases, payroll tax exposure, and U.S. Tax Court petitions for clients across Miami, Tampa, Jacksonville, Orlando, and every Florida county.
By Parham Khorsandi, Esq. — California Bar #266658. Last reviewed: . Attorney Advertising.
$100M+
Tax relief secured
2,000+
IRS cases handled
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U.S. Tax Court
Admitted, nationwide
If you owe federal tax in Florida, here's what changed for 2026
The IRS is back to full collection enforcement after the post-pandemic moratorium ended. Automated levies against Florida bank accounts, wage garnishments under IRC §6331, and passport revocations under IRC §7345 for seriously delinquent debt (over $64,000 in 2026) are running at pre-2020 volumes. Florida residents have no state income tax safety net — federal liability stands alone, and the Florida Constitution's homestead protection does not block a federal tax lien under United States v. Craft, 535 U.S. 274 (2002).
Federal collection statute (CSED) runs ten years under IRC §6502. Florida's own warrant collection clock under Section 95.091(3), Florida Statutes, runs five to twenty years depending on whether the warrant has been filed. Both clocks can be tolled. Pull your transcripts before negotiating.
Florida-specific federal tax practice
Florida is one of nine states with no personal income tax, which makes federal IRS representation the entire game for most individual Florida taxpayers. There is no Florida Franchise Tax Board to coordinate with on Form 1040 issues. The Florida Department of Revenue (FDOR) at floridarevenue.com handles only state-administered taxes: 5.5% corporate income tax under Chapter 220 of the Florida Statutes, 6% state sales and use tax under Chapter 212, reemployment (state unemployment) tax under Chapter 443, documentary stamp tax under Chapter 201, and the county-level tourist development tax under Section 125.0104.
Victory Tax Lawyers represents Florida residents and businesses in federal IRS matters through a Form 2848 Power of Attorney. Our lead attorney Parham Khorsandi is admitted to the California State Bar (license #266658) and the United States Tax Court — which gives nationwide trial-court access for federal income tax disputes. When a Florida client's case overlaps with state corporate income tax (Chapter 220) or sales tax (Chapter 212) issues at FDOR or the Florida Division of Administrative Hearings (DOAH), we coordinate with Florida bar members for state-tribunal appearances while keeping the federal side under our direct representation.
This page covers the federal IRS issues Florida taxpayers most commonly face, the state-level overlap with FDOR and DOAH, and how a Cal-Bar-admitted federal tax practice handles cases for clients in Miami-Dade, Broward, Palm Beach, Hillsborough, Orange, Duval, Pinellas, Lee, Leon, and every other Florida county.
Your rights as a Florida taxpayer
Federal taxpayer rights are codified in IRC §7803(a)(3), which directs the IRS Commissioner to ensure the Taxpayer Bill of Rights (TBOR) governs every interaction. The ten enumerated rights include the right to be informed, the right to quality service, the right to pay no more than the correct amount of tax, the right to challenge the IRS position, the right to appeal in an independent forum, the right to finality, the right to privacy, the right to confidentiality, the right to retain representation, and the right to a fair and just tax system.
Procedural rights you'll use most often as a Florida client:
- Right to representation under IRC §7521. You may have an attorney, CPA, or Enrolled Agent represent you at any IRS interview. Filing Form 2848 stops direct IRS contact and routes everything through counsel.
- Right to a Collection Due Process hearing under IRC §6320 (after Notice of Federal Tax Lien) and IRC §6330 (before levy). Filed on Form 12153 within 30 days of the IRS notice. Suspends collection and triggers Appeals review.
- Right to petition the U.S. Tax Court within 90 days of a Notice of Deficiency under IRC §6213. You do not have to pay the tax first — the prepayment-forum advantage that District Court refund suits lack.
- Right to recover litigation costs under IRC §7430 when the IRS position is not substantially justified.
- Right to a Taxpayer Advocate Service (TAS) referral when normal channels fail. Florida TAS offices serve from Jacksonville and Plantation; the National Taxpayer Advocate reports to Congress on IRS systemic failures.
For state-administered Florida tax matters, parallel rights flow from Chapter 213, Florida Statutes (administration) and Chapter 120 (administrative procedure). FDOR audits trigger a Notice of Proposed Assessment, a sixty-day informal protest window under Rule 12-6.0033, F.A.C., and a Chapter 120 petition right to DOAH for formal hearing.
How Victory Tax Lawyers helps Florida taxpayers
Offer in Compromise
Settle federal tax debt for less than owed under IRC §7122. We prepare Form 656 with 433-A(OIC) or 433-B(OIC) and represent through the centralized Memphis OIC unit. For Florida state corporate tax debt, we run a parallel §213.21 compromise through FDOR.
Installment Agreement
Federal installment plans under IRC §6159 — streamlined (under $50,000), regular, and partial-pay agreements that ride out the CSED. Filed on Form 9465 or directly with ACS.
Federal Tax Lien Resolution
Discharge, subordination, and withdrawal of Notices of Federal Tax Lien under IRC §6325 and §6323(j). Critical for Florida real-estate refinances and sales where the lien clouds title under Florida Statutes Chapter 695.
Levy and Garnishment Release
Stop wage levies and bank account seizures under IRC §6343 through Currently Not Collectible status, CDP requests under §6330, or installment agreement filings that suspend collection under §6331(k).
Audit Representation
Correspondence, office, and field audits at the Miami, Tampa, Jacksonville, and Orlando IRS examination groups. We respond to Information Document Requests, attend the audit, and file Appeals protests when the agent's adjustments miss the law.
Penalty Abatement
First-time abatement, reasonable cause under IRM 20.1.1, and statutory exceptions to IRC §6651 failure-to-file and failure-to-pay penalties. Florida hurricane disaster declarations under §7508A often unlock additional abatement grounds.
12 federal tax issues we handle for Florida taxpayers
Unfiled federal returns
Substitute for Return (SFR) assessments under IRC §6020(b) inflate liability. We reconstruct returns and supersede the SFR.
IRS audits
Florida small business and high-income individual audits run out of the Miami, Tampa, Jacksonville, and Orlando examination groups.
Notice of Deficiency response
90-day petition window under IRC §6213. Tax Court trials in Miami, Tampa, Jacksonville, and Tallahassee.
Trust Fund Recovery Penalty
IRC §6672 personal liability against Florida corporate officers, LLC members, and check-signers. Form 4180 interview defense.
Passport revocation
IRC §7345 seriously delinquent debt certification — critical for international Florida snowbirds and dual-residence clients.
Innocent spouse relief
IRC §6015 (b), (c), or (f) relief from joint and several liability — filed on Form 8857.
FBAR and FATCA
FinCEN Form 114 reporting for foreign accounts over $10,000; FATCA Form 8938 reporting. Streamlined Domestic and Foreign Offshore Procedures.
Cryptocurrency tax issues
Florida has no state crypto tax but federal IRS Notice 2014-21 and Rev. Rul. 2019-24 govern. Form 8300 cash reporting for trades above $10,000.
Florida sales tax audit overlap
FDOR sales tax audits under Chapter 212 often surface federal reporting gaps. We coordinate the federal Schedule C/1120 side.
Cannabis 280E exposure
Florida medical marijuana dispensaries face IRC §280E disallowance of ordinary business deductions. Cost of goods sold defense.
Estate and gift tax
Florida has no state estate tax (repealed 2004) but federal IRC §2001 and Form 706 still apply for estates above the federal exemption.
Cryptocurrency exchange 1099-DA
2026 broker reporting expansion under IRC §6045 catches Florida traders who omitted prior years. Voluntary disclosure paths.
9 common causes of federal tax debt for Florida clients
Florida's tourism, real estate, agriculture, and service economies generate predictable IRS exposure patterns. The nine fact patterns we see most often:
- Short-term rental income misreporting. Airbnb and Vrbo hosts in Miami Beach, Orlando, Destin, and Naples receive Form 1099-K and Form 1099-MISC but treat the income as casual rental rather than Schedule C or Schedule E. Audit adjustments catch the federal side while county tourist development tax catches the state side.
- Florida construction and contractor payroll tax. Independent-contractor misclassification under common-law agency tests (Rev. Rul. 87-41) leads to Form SS-8 reclassification and §6672 TFRP exposure for the owner.
- Snowbird residency-shift audits. Former residents of New York, New Jersey, Illinois, and California claim Florida domicile but former-state revenue departments aggressively audit the move. Federal residency for tax purposes (substantial presence test under IRC §7701(b)) is distinct from state residency.
- Foreign account non-disclosure. Latin American, Caribbean, and Israeli accounts held by Florida residents trigger FBAR and FATCA exposure when the IRS receives Form 8966 reports from foreign financial institutions.
- Cannabis and medical-marijuana business deductions disallowed. Florida licensed Medical Marijuana Treatment Centers (MMTCs) under Section 381.986, Florida Statutes, face IRC §280E denials of ordinary and necessary business expense deductions.
- Hurricane-related casualty deduction confusion. Florida disaster declarations under §7508A extend filing deadlines and allow casualty loss claims under §165(h), but improper claims trigger §6662 accuracy penalties.
- Real estate flip income reported as capital gain. Active Florida real estate investors who flip more than two or three properties per year may be reclassified as dealers under §1221(a)(1) — ordinary income rates and self-employment tax.
- Identity theft and fraudulent return filings. Florida is among the top three states for tax-related identity theft per IRS Publication 4524. IP PINs under §6103 and Form 14039 affidavits required.
- Estate income post-death. Probate estates under Florida Probate Code (Chapter 731 et seq., Florida Statutes) trigger Form 1041 fiduciary returns that surviving family often misses.
Who owes the tax — 8 Florida liability scenarios
Individual federal liability
IRC §6001 imposes the income tax on individuals. Florida has no parallel personal liability — the state constitution forbids it.
Joint and several liability of spouses
IRC §6013(d)(3) holds each joint filer fully liable. Innocent spouse relief under §6015 is the only out.
Trust Fund Recovery (§6672)
Personal liability for any "responsible person" who willfully fails to pay over withheld payroll tax. Florida bookkeepers and CFOs included.
Florida corporate income tax (Chapter 220)
C-corporations doing business in Florida owe 5.5% under Section 220.11. S-corps and most LLCs pass through to federal only.
Florida sales tax officer liability
Section 213.29, Florida Statutes, imposes personal liability on corporate officers who willfully fail to collect or remit sales tax.
Successor liability under §6324 and Section 213.758
Buyers of Florida businesses inherit unpaid federal and state tax unless a bulk-sale notice is filed.
Transferee liability (§6901)
Recipients of fraudulent or below-value transfers pay the transferor's tax — enforceable in U.S. District Court.
Decedent and estate liability
Final Form 1040 plus estate Form 1041 plus Form 706 for taxable estates. Florida probate under Chapter 733 governs payment priority.
What resolution can look like
Debt reduced
Offer in Compromise settlements close the federal debt below assessed balance. Partial-pay installment agreements ride out the CSED and discharge the remainder. Florida §213.21 compromises run parallel for state corporate or sales tax exposure.
Penalties abated
First-time abatement, reasonable cause, and statutory exceptions remove failure-to-file (§6651(a)(1)), failure-to-pay (§6651(a)(2)), and accuracy-related (§6662) penalties. Florida hurricane disaster relief under §7508A unlocks additional grounds.
Liens and levies released
Notice of Federal Tax Lien withdrawal under §6323(j), lien discharge under §6325(b) for Florida real estate sales, and bank or wage levy releases under §6343 once a collection alternative is in place.
Recent representative results
| Year | Debt | Resolution type | Outcome | Authority |
|---|---|---|---|---|
| 2024 | $284,500 | Offer in Compromise | Accepted at $18,200 | IRC §7122 doubt as to collectibility |
| 2024 | $96,750 | Partial Pay Installment Agreement | $150/month through CSED | IRC §6159 PPIA, balance discharged at CSED |
| 2023 | $412,300 | Currently Not Collectible | Collection suspended | IRC §6343 hardship, no levy through 2026 |
| 2023 | $67,400 | Penalty Abatement | Penalties removed ($14,200) | First-time abatement + reasonable cause |
| 2024 | $1.2M | Tax Court petition + Appeals settlement | Settled at $176,000 | IRC §6213 deficiency petition, Appeals concession |
Past results do not guarantee similar outcomes. Each tax matter turns on individual facts including the assessment date, asset position, compliance history, and applicable IRC provisions. Figures are anonymized; firm aggregate $100M+ in tax relief secured across 2,000+ federal IRS engagements.
Why a Cal-Bar-admitted firm handles Florida federal tax cases
Federal tax practice before the IRS is governed by Treasury Department Circular 230 (31 CFR Part 10), not by state bar lines. Any attorney admitted in any state, plus Enrolled Agents and CPAs, may represent a Florida taxpayer before the IRS through a Form 2848 Power of Attorney. The relevant credentials for federal tax work are:
- Active state bar admission — Parham Khorsandi, California Bar #266658, verified at apps.calbar.ca.gov.
- U.S. Tax Court admission under Tax Court Rule 200 — nationwide federal trial-court access for IRC §6213 deficiency petitions and §6330(d) CDP appeals.
- Circular 230 compliance — §10.3 (eligible practitioners), §10.35 (written advice standards), §10.37 (advertising rules).
For Florida state tax matters — Chapter 220 corporate income tax, Chapter 212 sales tax, Chapter 443 reemployment tax, or county tourist development tax — administrative hearings under Chapter 120, Florida Statutes, take place at the Florida Division of Administrative Hearings (DOAH). State circuit court appeals run through the Leon County Circuit Court under Section 72.011, Florida Statutes. When a case requires DOAH or Florida circuit court appearance, we engage Florida-admitted co-counsel while keeping the federal IRS side under direct VTL representation.
Florida clients get the same Cal-Bar-admitted federal tax attorney handling Notice of Deficiency petitions, Appeals conferences, Collection Due Process hearings, and U.S. Tax Court trials in Miami, Tampa, Jacksonville, and Tallahassee — with the nationwide reach the U.S. Tax Court Bar provides.
Our 7-step Florida federal tax engagement
1. Free initial consultation
Call (800) 883-8301. We listen to the situation, identify the IRS notice type, and outline the realistic resolution options before any retainer.
2. Engagement letter and fee agreement
Flat fee or hourly, scoped to the issue. Written engagement under California Rules of Professional Conduct 1.5(b).
3. Form 2848 Power of Attorney filed
Authorizes direct IRS contact, stops calls and letters to the client, and provides Centralized Authorization File (CAF) access.
4. Transcript pull and CSED calculation
Form 8821 or 2848 grants transcript access. We calculate the IRC §6502 ten-year collection statute date for each tax year.
5. Strategy memo
Written analysis of OIC, IA, CNC, Tax Court, Appeals, and penalty abatement options. Florida-specific overlay where state tax issues exist.
6. Negotiation or litigation
File the action — Form 656 OIC, Form 12153 CDP, Tax Court petition, Appeals protest, or §213.21 Florida compromise.
7. Compliance monitoring
Five-year post-OIC compliance under §7122(d). Future-return filing reminders. Default-cure procedures if an installment agreement slips.
Collection statute of limitations warning
Under IRC §6502, the IRS has ten years from the assessment date to collect federal tax. After CSED, collection ceases by operation of law. But the clock tolls during an Offer in Compromise (until rejection plus 30 days), a Collection Due Process hearing, bankruptcy, and absence from the country for over six months.
Florida has its own collection clock: Section 95.091(3), Florida Statutes, gives FDOR five years from the date of assessment to issue a warrant and twenty years to enforce a recorded warrant. Bankruptcy and installment agreements toll the state clock too.
Pull your IRS account transcript and your Florida tax warrant search results before negotiating anything. Knowing the end date drives the strategy: a debt with twelve months to CSED gets a CNC filing or partial-pay IA; a debt with eight years to CSED gets an OIC analysis.
Florida federal and state tax venues
Federal tax cases involving Florida clients run through the following venues:
- U.S. Tax Court — trial sessions in Miami (Claude Pepper Federal Building, 51 SW 1st Ave, Room 1524), Tampa (Timberlake Federal Annex, 501 E Polk St, Room 1201), Jacksonville (300 N Hogan St, Room 6A), and Tallahassee.
- U.S. District Court — Southern District of Florida (Miami, Fort Lauderdale, West Palm Beach), Middle District of Florida (Tampa, Orlando, Jacksonville, Fort Myers), Northern District of Florida (Tallahassee, Pensacola, Panama City). Refund suits under 28 U.S.C. §1346(a)(1) after full payment.
- U.S. Court of Federal Claims — alternative refund venue in Washington, D.C.
- IRS Independent Office of Appeals — administrative settlement before litigation.
IRS Taxpayer Assistance Centers in Florida: Miami (51 SW First Ave, Suite 311), Tampa (3848 W. Columbus Drive), Jacksonville (400 West Bay St), Plantation (1248 N. University Drive). Appointments required at apps.irs.gov/app/office-locator or (844) 545-5640.
State-administered Florida tax disputes run through:
- Florida Department of Revenue (floridarevenue.com) — informal protest under Rule 12-6.0033, F.A.C.
- Florida Division of Administrative Hearings (DOAH) (doah.state.fl.us) — formal Chapter 120 hearings before Administrative Law Judges. Final hearings typically calendared in six to nine months.
- Leon County Circuit Court — Section 72.011, Florida Statutes, alternative judicial review of FDOR assessments.
- Florida District Courts of Appeal — First DCA (Tallahassee) hears most state-tax appeals from circuit court.
Free Florida tax consultation
90 days from a Notice of Deficiency to file in U.S. Tax Court. 30 days from a CDP notice to request a hearing. CSED clocks keep running. Call today.
Florida tax attorney FAQs
Does Florida have a state personal income tax?
No. Article VII, Section 5 of the Florida Constitution prohibits a state personal income tax on individuals. That means most Florida residents only deal with federal income tax matters through the IRS, not a state revenue agency. Florida does levy a 5.5% corporate income tax under Chapter 220 of the Florida Statutes and a 6% state sales and use tax under Chapter 212. So while individuals get a pass on state income filing, businesses and consumers still answer to the Florida Department of Revenue (FDOR).
Where is the closest U.S. Tax Court trial session held in Florida?
The U.S. Tax Court holds regular trial sessions in four Florida cities: Jacksonville (U.S. District Court Clerk, 300 N Hogan St, Room 6A), Miami (Claude Pepper Federal Building, 51 SW 1st Ave, Room 1524), Tampa (Timberlake Federal Annex, 501 E Polk St, Room 1201), and Tallahassee on a less frequent rotation. A Notice of Deficiency from the IRS triggers a 90-day window to file under IRC §6213. We file the petition in Washington, D.C. and request a Florida trial location during calendaring.
Can the IRS and the Florida Department of Revenue audit me for the same tax year?
Yes, but the audits cover different liabilities. The IRS examines your federal income tax return. FDOR examines state-administered taxes — corporate income (if you own a corporation), sales and use, reemployment (state unemployment), tourist development, and documentary stamp tax. The two agencies share information under IRC §6103(d) and Florida Statutes Chapter 213. A federal audit adjustment that increases income often triggers a Florida corporate audit if you operate as a C-corporation. We handle both tracks through a single engagement with a Form 2848 IRS Power of Attorney and a Form DR-835 Florida Power of Attorney.
Does Florida have an Offer in Compromise equivalent for state tax debt?
Yes. Section 213.21, Florida Statutes, authorizes the Executive Director of the Florida Department of Revenue to compromise tax, interest, and penalty assessments on two grounds: doubt as to liability and doubt as to collectibility. Settlements above $30,000 must be in writing; smaller compromises can be informal but the department maintains records of every settlement. The state OIC parallels the federal Offer in Compromise under IRC §7122. We file both when a Florida business owes both layers — federal payroll tax under §7501 and state sales tax under Chapter 212.
What is the IRS collection statute of limitations and does Florida have its own?
Federal collection runs ten years from the assessment date under IRC §6502. After that, the IRS loses the legal right to collect. Florida has its own collection clock: Section 95.091(3), Florida Statutes, gives FDOR five years to issue a warrant and twenty years to enforce a warrant once filed. Both clocks can be tolled — federally by an Offer in Compromise, Collection Due Process hearing, bankruptcy, or absence from the country; in Florida by bankruptcy or an installment agreement. Pull your IRS account transcript and your Florida tax warrant search results before negotiating. The end date drives the strategy.
I'm a snowbird splitting time between Florida and another state — which state can tax my income?
Residency drives state income tax exposure. A state with an income tax can claim you as a resident if you spend more than 183 days there in a calendar year, maintain a home there, or treat it as your domicile under the state's facts-and-circumstances test. Florida's lack of a state income tax is a strong pull, but former domicile states (especially New York, California, New Jersey, Illinois) audit aggressively when you claim a Florida move. We work with Florida-based estate-planning counsel on domicile evidence: voter registration in Florida, driver's license under Chapter 322, homestead exemption filing, Florida-based financial accounts, and the Declaration of Domicile under Section 222.17, Florida Statutes. Federal tax issues we handle ourselves.
Does Florida have an estate tax or inheritance tax?
No. Florida repealed its estate tax in 2004 when the federal credit for state death taxes was phased out, and there has never been a Florida inheritance tax. Federal estate tax under IRC §2001 still applies to estates above the federal exemption ($13.99 million per individual in 2025; verify the current figure with IRS Form 706 instructions). For high-net-worth Florida estates we focus on federal estate tax planning, GST issues under IRC §2601, and proper basis step-up reporting. State-level estate filings are not required.
Where are the IRS Taxpayer Assistance Centers in Florida?
Florida has TACs in Miami (51 SW First Ave, Suite 311), Tampa (3848 W. Columbus Drive), Jacksonville (400 West Bay St), Plantation (1248 N. University Drive), and rotating sites in Orlando, Fort Lauderdale, and St. Petersburg. Appointments are required — call (844) 545-5640 to book. TACs handle ITIN reviews, transcript pulls, payment options, and identity verification. They do not provide legal advice. For substantive resolution work we engage with the IRS through Form 2848 Power of Attorney rather than TAC walk-ins.
What happens if I owe Florida sales tax and cannot pay?
Florida sales tax delinquency is treated harshly because the tax is held in trust under Section 212.15, Florida Statutes — the merchant collects it for the state. Failure to remit can lead to criminal charges under Section 212.15(2) (theft of state funds) and personal liability for corporate officers under Section 213.29. FDOR can revoke your sales tax certificate of registration, file a warrant, and levy bank accounts. Section 213.21 still allows a compromise, but timing matters. We negotiate stipulated payment agreements and pursue penalty waivers under Section 213.21(3)(a) for reasonable cause.
What is the Trust Fund Recovery Penalty and how does it apply to Florida business owners?
IRC §6672 imposes personal liability on "responsible persons" who willfully fail to collect or pay over federal employment taxes — withheld income tax and the employee share of FICA. The penalty equals 100% of the unpaid trust fund taxes. Florida corporate officers, members of LLCs, bookkeepers, and check-signers can all qualify as responsible persons. We defend TFRP assessments through Form 4180 interviews, Appeals protests under Pub 5, and §7433 wrongful collection claims when the IRS overreaches. The IRS coordinates with FDOR when a Florida business also owes state reemployment tax under Chapter 443.
Can the IRS take my Florida homestead to collect federal tax debt?
Florida's homestead exemption under Article X, Section 4 of the Florida Constitution is one of the strongest in the country — it blocks most creditors. But federal tax liens are different. The Supremacy Clause and IRC §6321 allow the IRS to attach a federal tax lien to all property, including Florida homestead. The Supreme Court confirmed this in United States v. Craft, 535 U.S. 274 (2002). The IRS rarely forces a sale of a primary residence because of administrative restraints in IRC §6334(e) and the principal residence policy in IRM 5.10.1, but the lien clouds title and survives sale. We pursue lien subordination, discharge under §6325, and Certificate of Discharge filings when a refinance or sale is needed.
What is a Florida tax warrant and how is it different from a federal tax lien?
A Florida tax warrant is filed by FDOR under Section 213.731, Florida Statutes, with the clerk of the circuit court in the county where the taxpayer has assets. Once recorded, it operates like a judgment lien for twenty years under Section 95.091(3). A federal tax lien under IRC §6321 attaches automatically when the IRS assesses tax, demand is made, and the taxpayer fails to pay; the Notice of Federal Tax Lien filed under §6323 perfects priority against third parties. Both clouds title to real property in Florida. We file Form 12277 to request federal NFTL withdrawal under §6323(j) and petition FDOR for warrant satisfaction once the underlying liability resolves.
Do I need a Florida-licensed attorney or can a California attorney represent me in IRS matters?
Federal tax practice before the IRS is governed by 31 CFR Part 10 (Circular 230), not state bar admission. Any attorney admitted in any state — plus CPAs and Enrolled Agents — can represent a Florida taxpayer before the IRS through Form 2848 Power of Attorney. Cal Bar admission is sufficient. U.S. Tax Court admission is a separate federal credential under Tax Court Rule 200 and grants nationwide trial-court access. State-level Florida tax matters before FDOR or DOAH may require Florida-licensed counsel under Chapter 120, Florida Statutes; we partner with Florida bar members when state-tribunal litigation is needed.
How does Florida's tourist development tax ("bed tax") affect short-term rental owners?
Counties in Florida (e.g., Miami-Dade, Orange, Pinellas, Broward) impose a tourist development tax of 2% to 6% on rentals of six months or less under Section 125.0104, Florida Statutes. Airbnb and Vrbo collect and remit in some counties but not all. Owners filing their own returns directly to the county tax collector face audit exposure when remittance dates are missed. We see this pattern frequently in Orlando, Miami Beach, and Naples. The federal side is reported on Schedule E or Schedule C of Form 1040; we coordinate the federal and Florida county filings so the audit trail is consistent.
About the author
Parham Khorsandi, Esq. is the founding attorney of Victory Tax Lawyers, LLP. He is admitted to the State Bar of California (license #266658) and the United States Tax Court. His federal practice covers Offer in Compromise, installment agreements, audit defense, Collection Due Process hearings, Tax Court petitions, payroll tax exposure, and FBAR/FATCA disclosure. He represents clients in all 50 states through Form 2848 Power of Attorney and U.S. Tax Court nationwide jurisdiction, including Florida residents and businesses in Miami, Tampa, Jacksonville, Orlando, St. Petersburg, Hialeah, Tallahassee, and Fort Lauderdale.
Reviewed by: Parham Khorsandi, Esq. — California Bar #266658 — verify on calbar.ca.gov.
Last reviewed: .
Attorney Advertising. This page is provided for general informational purposes only and does not constitute legal advice. Reading this page or contacting Victory Tax Lawyers, LLP does not create an attorney-client relationship. An attorney-client relationship is formed only by a written engagement signed by both parties.
IRS Circular 230 Disclosure: The discussion of U.S. federal tax issues in this content is not intended 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 person any transaction or matter addressed. For specific tax advice, consult independent tax counsel.
Past results. Past results do not guarantee similar outcomes. Each tax matter turns on individual facts including assessment date, asset position, compliance history, and applicable IRC provisions.
Jurisdiction. Victory Tax Lawyers, LLP is a California limited liability partnership. Lead attorney Parham Khorsandi is admitted in California (Bar #266658) and to the United States Tax Court. Federal IRS representation is provided in all 50 states under Treasury Department Circular 230 (31 CFR Part 10). Florida state-tax matters before the Florida Department of Revenue, Florida Division of Administrative Hearings, or Florida courts may require co-counsel admitted to the Florida Bar.
Related federal tax services
Cities we serve in Florida
Victory Tax Lawyers represents Florida taxpayers before the IRS, U.S. Tax Court, and federal tax authorities. Federal practice is not constrained by state-bar admission — under 31 CFR §10.3 (Circular 230), our attorneys may represent Florida taxpayers on federal tax matters through a Form 2848 Power of Attorney.