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Tax Attorney in Fort Lauderdale, FL

Federal IRS representation for Fort Lauderdale, Broward County, and the wider South Florida metro — audits, back taxes, Offer in Compromise filings, liens, levies, FBAR and Streamlined Filing Compliance Procedures for yacht-industry crews and Caribbean account holders, Trust Fund Recovery Penalty defense, and U.S. Tax Court petitions filed in the Miami trial city. Florida has no state personal income tax, so individual filers in Fort Lauderdale face a pure federal IRS posture for income matters. Businesses still deal with the Florida Department of Revenue on the 5.5% corporate income tax, the 6% state sales-and-use tax plus the 1% Broward County discretionary surtax (7% effective), Documentary Stamp Tax on deeds and mortgages, and reemployment tax on payroll.

By Parham Khorsandi, Esq. — California Bar #266658. Admitted to practice before the United States Tax Court. Last Reviewed: .

5.0 rating from 72 client reviews $100M+ in tax relief secured 2,000+ cases resolved

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Jurisdiction: Federal IRS practice in Fort Lauderdale and Broward via Form 2848 PoA; U.S. Tax Court Miami sessions Free consultation: (800) 883-8301 Last Reviewed:

Fort Lauderdale taxpayers facing IRS collection, FBAR exposure, or Florida DOR action — what 2026 looks like

Passport-revocation referrals under IRC §7345 resumed at full volume for federal tax debts above the 2026 threshold of roughly $62,000 — a problem for Fort Lauderdale yacht brokers and captains traveling between U.S. ports and the Bahamas, cruise-industry officers at Port Everglades, AutoNation executives at the Las Olas headquarters, Citrix Systems alumni still vesting equity, and Brazilian, Haitian, Jamaican, and Bahamian dual-citizen households that move on and off the islands monthly. The IRS also reactivated automated levy programs under IRC §6331, with bank levies holding for 21 days before remittance. FBAR enforcement under 31 USC §5314 and Form 8938 enforcement under IRC §6038D stay active in Broward given the volume of foreign-flagged-yacht LLC accounts and Caribbean depositary banking. On the state side, the Florida Department of Revenue is auditing sales-tax sourcing for Fort Lauderdale Beach short-term rentals, the 5.5% Florida corporate income tax on Broward C-corps, charter-yacht sales-and-use tax exposure under Fla. Stat. Chapter 212, and Documentary Stamp Tax on Las Olas and Victoria Park luxury closings. Getting in front of either enforcement track before the levy or seizure hits is materially easier than reversing it afterward.

$100M+

Total tax relief secured

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Tax cases resolved

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Average rating · 72 reviews

All 50

States via Form 2848 PoA

Past results do not guarantee future outcomes. Each tax case is unique and turns on individual facts and IRS discretion.

Why city-specific federal tax representation matters in Fort Lauderdale

Victory Tax Lawyers, LLP is a California-licensed tax-law firm whose primary practice is federal IRS controversy and resolution. We represent Fort Lauderdale individuals and Broward County businesses before the Internal Revenue Service, the U.S. Tax Court, and the IRS Independent Office of Appeals through a Form 2848 Power of Attorney, which is recognized at every IRS Compliance Center and Service Center nationwide. Federal tax practice is not bound by state-bar admission: under 31 CFR §10.3 (Circular 230), attorneys, certified public accountants, and enrolled agents may represent taxpayers before the IRS regardless of the taxpayer's state of residence.

Fort Lauderdale's tax-controversy profile is shaped by a single industry that has no real analog elsewhere in the United States: the yacht trade. Fort Lauderdale is the yacht capital of the world — home to the Fort Lauderdale International Boat Show, the largest in-water boat show on the planet, plus a year-round megayacht refit and brokerage cluster along the 17th Street Causeway and the New River. The federal tax issues that follow are dense: 1099-NEC reporting for independent yacht brokers, IRC §263A UNICAP capitalization for new-build and refit inventory, IRC §1031 like-kind exchanges on charter-yacht trade-ups (limited to real property after the 2017 TCJA, but legacy transactions still in audit), and FBAR reporting for foreign-flagged-yacht-holding LLCs domiciled in the Cayman Islands, British Virgin Islands, or Marshall Islands.

Port Everglades adds another layer. The port is the second-busiest cruise port in the world, home base for Royal Caribbean (Symphony of the Seas, Wonder of the Seas), Princess Cruises, Holland America, and Celebrity. Cruise-line shoreside officers, foreign-flagged-vessel crew, and the surrounding logistics and provisioning ecosystem all carry international-payroll, foreign-earned-income, and FBAR exposure. Add the AutoNation corporate headquarters (the largest auto retailer in the United States, headquartered on East Las Olas Boulevard), Citrix Systems' long Fort Lauderdale tenure and its post-merger Cloud Software Group successor still operating from the city, and several large healthcare systems — Broward Health, Memorial Healthcare System, Holy Cross Health, and Cleveland Clinic Florida in nearby Weston — that issue heavy 1099 volume to surgeon and physician contractors.

Fort Lauderdale also hosts the largest per-capita LGBT+ population in the United States in Wilton Manors and across the wider city. Federal joint-filing under IRC §6013, estate planning under the unified credit, gift-splitting, and spousal portability all become routine practice points. Layered on top: post-2020 relocation flows from New York, New Jersey, Illinois, and Massachusetts driven by Florida's lack of state personal income tax, plus established Brazilian, Haitian, Bahamian, Jamaican, and Hispanic communities that bring FBAR, ITIN, and Streamlined Filing Compliance volume.

If your problem is federal, you do not need an attorney admitted in Florida. You need an attorney with U.S. Tax Court bar admission and federal-practitioner credentials under Circular 230. That is what this firm provides — with twenty-plus years of focused federal tax controversy work and a workflow built to operate remotely so that geography never delays your case.

Your tax rights as a Fort Lauderdale taxpayer

Federal taxpayer rights are codified across the Internal Revenue Code and summarized in IRS Publication 1, the Taxpayer Bill of Rights. They apply identically in Las Olas, Victoria Park, Coral Ridge, Wilton Manors, Rio Vista, Harbor Beach, the 17th Street marine district, or any other Fort Lauderdale neighborhood. The rights you can actually invoke during a controversy:

Right to representation

Under IRC §7521(b)(2), an IRS examiner or Revenue Officer must stop an interview when you state you wish to consult with an authorized representative. A signed Form 2848 puts your tax attorney between you and the IRS for the duration of the matter, including any field-collection visit to your Las Olas office or Coral Ridge home.

Right to Collection Due Process

After a Notice of Federal Tax Lien (IRC §6320) or a Final Notice of Intent to Levy (IRC §6330), you have 30 days to request a Collection Due Process hearing on Form 12153. CDP requests pause collection enforcement and preserve a path to U.S. Tax Court review of the Appeals determination.

Right to U.S. Tax Court review

A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). Filing a petition in Tax Court means you can litigate without paying the deficiency first. The U.S. Tax Court holds no permanent Fort Lauderdale session; Broward petitioners typically designate Miami or Tampa as the place of trial, and Miami sits at the Wilkie D. Ferguson Jr. U.S. Courthouse, 400 N. Miami Avenue.

Right to an Offer in Compromise

Under IRC §7122, the IRS may accept less than the full liability where doubt as to collectibility, doubt as to liability, or effective tax administration justifies settlement. The offer is filed on Form 656 with Form 433-A(OIC) or Form 433-B(OIC) financial disclosure.

Right to a Collection Statute

IRC §6502 gives the IRS ten years from the date of assessment to collect, after which the federal debt becomes uncollectible. Several events toll the period: pending OICs, bankruptcy, CDP hearings, and military deployment. Pull your IRS Account Transcripts to verify your Collection Statute Expiration Date before negotiating any resolution.

Right to disaster relief postponement

Under IRC §7508A, the IRS may postpone filing, payment, and assessment deadlines for taxpayers in federally declared disaster areas. Broward County triggered this for Hurricane Ian 2022, Hurricane Idalia 2023, Hurricane Helene 2024, and Hurricane Milton 2024 — statute-of-limitations postponements from those declarations continue to interact with current cases.

How Victory Tax Lawyers helps Fort Lauderdale taxpayers

Offer in Compromise

We prepare and file Form 656 with the supporting Form 433 financials under IRC §7122. The IRS evaluates Reasonable Collection Potential using your monthly income net of allowable expenses plus the realizable value of assets — a calculation that frequently misses depreciated yacht-brokerage receivables, illiquid AutoNation or Citrix-successor RSUs that have not vested, and equity in Las Olas or Coral Ridge real estate held through family-limited partnerships. We pressure-test the math before submission so the offer reaches Appeals if it is rejected at intake.

Installment Agreement

Streamlined IAs under $50,000, Non-Streamlined IAs over $50,000 with Form 433-F disclosure, and Partial Pay Installment Agreements under IRC §6159 that run only through the CSED. For Fort Lauderdale yacht brokers with commission income that arrives in lumpy six-figure tranches, cruise-line shoreside professionals on seasonal cycles, and Cleveland Clinic Florida 1099 physicians with quarterly-estimate gaps, the structure choice matters as much as the monthly number.

FBAR and Streamlined Filing

A signature Fort Lauderdale federal-tax practice. We handle FinCEN Form 114 (FBAR) filings, Form 8938 statements under IRC §6038D, Streamlined Foreign Offshore submissions for U.S. citizens living abroad, Streamlined Domestic Offshore submissions for non-willful Broward residents with foreign accounts, and IRS Voluntary Disclosure Practice for willful exposure. Foreign-flagged-yacht-holding LLCs in the Cayman Islands, BVI, Marshall Islands, or Isle of Man carry FBAR exposure for U.S. owners and signatories even when the yacht itself does not sit in U.S. waters.

Lien release and withdrawal

A Notice of Federal Tax Lien under IRC §6321 attaches to your Broward County real estate, vehicles, brokerage accounts, and personal property — including documented vessels under Coast Guard registry. We pursue release after payment, certificate of discharge for specific property (frequently used for refinancing a Rio Vista or Harbor Beach home), subordination to allow refinancing, and lien withdrawal under the Fresh Start program for IAs of $25,000 or less.

Levy release

Wage levies (CP90 / LT11 series) and bank levies under IRC §6331 stop when we secure Currently Not Collectible status, an accepted IA, an accepted OIC, or a timely CDP request. Time matters: bank levies hold for 21 days before remittance under IRC §6332(c), which is your window to act.

Penalty abatement

First-Time Penalty Abatement administrative relief and Reasonable Cause requests under IRC §6651 and §6662. Reasonable-cause arguments for Fort Lauderdale filers frequently rest on Hurricane Ian 2022, Idalia 2023, Helene 2024, and Milton 2024 disaster declarations, serious medical illness, and reliance on a tax preparer (subject to United States v. Boyle limits).

Twelve types of Fort Lauderdale tax issues we handle

Federal IRS practice areas, framed for the Broward economy.

Yacht broker 1099 reporting

Independent yacht brokers along the 17th Street and New River corridors receive 1099-NEC commission income that often arrives in single six-figure tranches with no withholding. Quarterly-estimate failures under IRC §6654, Schedule C deductibility audits, and Trust Fund exposure for brokerages with employees are recurring issues.

UNICAP for yacht refit and inventory

IRC §263A requires capitalization of indirect costs into yacht refit and new-build inventory for producers and brokerage inventory above the small-business threshold. Fort Lauderdale shipyards along the New River and the Dania Cut-Off Canal regularly face IRS adjustment proposals on UNICAP method changes and absorption ratios.

Charter yacht §1031 legacy

Pre-2018 like-kind exchanges of charter yachts under IRC §1031 remain in audit for taxpayers who exchanged personal property before the TCJA limited §1031 to real property. Cost-segregation studies, basis carryover, and qualified-intermediary documentation drive these cases.

Foreign-flagged-yacht LLC FBAR

U.S. owners and signatories on Cayman Islands, British Virgin Islands, Marshall Islands, and Isle of Man yacht-holding LLCs trigger FBAR reporting on the LLC's foreign bank accounts under 31 USC §5314 and Form 8938 reporting under IRC §6038D, plus Form 5471 controlled-foreign-corporation reporting where the LLC elects corporate treatment.

Port Everglades cruise FBAR

Royal Caribbean, Princess, Holland America, and Celebrity shoreside officers earning paid-leave entitlements through foreign-domiciled subsidiaries, plus crew members holding foreign bank accounts during contract rotations, generate FBAR and Form 8938 exposure across Bahamian, Panamanian, Bermudian, and Filipino account jurisdictions.

AutoNation and Citrix RSU under-withholding

AutoNation (Las Olas HQ) and Citrix Systems / Cloud Software Group employees in Fort Lauderdale face under-withholding on restricted stock units that vest at concentrated prices, ISO exercise with alternative minimum tax exposure under IRC §55, and §83(b) election deadlines on early-exercise grants and pre-IPO acquisitions.

Cleveland Clinic and Broward Health 1099 physicians

Surgeons and physicians at Cleveland Clinic Florida (Weston), Broward Health, Memorial Healthcare System, and Holy Cross Health on 1099-NEC contracts owe quarterly estimates, self-employment tax under IRC §1401, and qualified-retirement-plan elections. Schedule C versus S-corp election decisions move tens of thousands per year.

Federal tax liens on Broward property

NFTLs recorded with the Broward County Records, Taxes and Treasury Division cloud title on homes in Las Olas, Coral Ridge, Harbor Beach, Rio Vista, Wilton Manors, and the Galt Ocean Mile — blocking refinancing and sale at a moment when South Florida valuations remain volatile.

Passport revocation defense

IRC §7345 certifications block international travel for Fort Lauderdale yacht brokers running boats to the Bahamas and Caribbean, cruise-line officers based at Port Everglades, and dual-citizen households commuting to Sao Paulo, Port-au-Prince, Kingston, Nassau, or Bogota.

Trust Fund Recovery Penalty

IRC §6672 reaches anyone with check-signing authority over a Fort Lauderdale business that fell behind on Form 941 trust funds. Marine-services shops at Lauderdale Marine Center, charter brokerages, restaurants along Las Olas and the beach, and Wilton Manors hospitality operators see this regularly.

Fort Lauderdale Beach STR sales-tax

Airbnb and VRBO operators in Fort Lauderdale Beach, Las Olas Isles, and the Galt Ocean Mile owe Florida 6% state sales tax plus the 1% Broward discretionary surtax plus Broward tourist development tax. Failures cascade into Schedule E federal exposure and Florida DOR responsible-person liability under Fla. Stat. §213.29.

Hurricane casualty losses

Personal-use casualty losses for federally declared disasters under IRC §165(h) — Ian 2022, Idalia 2023, Helene 2024, and Milton 2024 — plus IRC §1033 involuntary-conversion treatment for waterfront-home and dockage replacement. Open-year amendments still feasible in many Broward claims.

Nine common causes of tax debt in the Fort Lauderdale metro

1. Yacht-broker commission lumpiness

A 17th Street yacht broker books two megayacht closings in October, then nothing until April. The 1099-NEC arrives without any withholding, the §6654 quarterly-estimate threshold blows through, and the April 15 balance becomes a six-figure problem that compounds with penalty and interest.

2. Unreported foreign-yacht-LLC accounts

A Fort Lauderdale owner holds a megayacht through a Cayman Islands or BVI LLC for liability and registry purposes. The LLC opens a corporate bank account offshore for fuel, dockage, and crew payroll. Aggregate balances over $10,000 trigger FBAR under 31 USC §5314 — routinely missed for years.

3. RSU and bonus under-withholding

An AutoNation executive on East Las Olas or a Citrix-successor engineer in the Cypress Creek corridor receives a multi-million-dollar RSU vest. Employer withholding at the 22% supplemental rate falls short of the 37% top marginal rate plus the 3.8% net-investment-income tax under IRC §1411, leaving a six- or seven-figure April balance.

4. Short-term rental sales tax

A Fort Lauderdale Beach, Las Olas Isles, or Wilton Manors Airbnb operator owes Florida 6% state sales tax plus Broward 1% discretionary surtax plus county tourist development tax. Failure to register and remit triggers Florida DOR responsible-person liability and federal Schedule E exposure on filed returns.

5. Real-estate sale without §1031

The South Florida real-estate run-up from 2020 through 2024 generated surprise capital gains for investors who sold Las Olas, Victoria Park, or Coral Ridge rentals without a like-kind exchange under IRC §1031. Foreign sellers add FIRPTA withholding under §1445 on top.

6. ERC clawback exposure

Employee Retention Credit claims pushed by promoter mills are being clawed back through CP207 and CP207L letters. Fort Lauderdale marine-services shops, charter brokerages, Las Olas restaurants, beachfront hospitality, and dental practices face the recapture wave.

7. Misclassified worker disputes

IRS audit reclassifies 1099 contractors as W-2 employees under common-law factors. Fort Lauderdale yacht-crew agencies, marine-services contractors, home-health franchises, and Cleveland Clinic Florida-adjacent staffing firms face retroactive payroll-tax assessments back three years.

8. Hurricane-disrupted filing

Broward filers missed deadlines after Ian 2022, Idalia 2023, Helene 2024, and Milton 2024. Disaster-zone postponements under IRC §7508A help, but unfiled-return penalty stacks accumulate quickly when the extension window lapses without action.

9. NY/NJ/IL/MA relocation gaps

A post-2020 relocator moves a primary residence and W-2 income from New York, New Jersey, Illinois, or Massachusetts to a Fort Lauderdale address mid-year. Part-year resident filings, statutory-residency audits from the prior state, and dual-state withholding mismatches all drive surprise federal and state-of-origin balances.

Who is on the hook: eight tax-liability scenarios for Fort Lauderdale filers

Joint filers and joint-and-several liability

Joint federal returns create joint-and-several liability under IRC §6013(d)(3). One spouse can be pursued for the entire balance. Florida is not a community-property state, so Innocent Spouse Relief analysis under IRC §6015 turns on actual knowledge and benefit rather than the community-income complications that arise in Texas or California. Wilton Manors and broader Fort Lauderdale joint filers see this pattern frequently in estate-planning and divorce work.

Responsible persons for payroll

Trust Fund Recovery Penalty under IRC §6672 reaches anyone who had check-signing authority over a Fort Lauderdale business and willfully failed to pay over withheld federal taxes — not just officers. Office managers at yacht brokerages, fractional CFOs at marine-services groups, and PEO contacts can all be assessed personally.

Florida sales-tax responsible person

Under Fla. Stat. §213.29, officers and directors of an entity that collects sales tax in trust and fails to remit can be held personally liable for a penalty equal to 200% of the unpaid tax. Fort Lauderdale restaurants, charter brokerages, marine-supply shops, and short-term-rental managers see this through Florida DOR audits.

Transferee liability

IRC §6901 reaches a transferee of assets where the transfer rendered the transferor insolvent and tax debts remain unpaid. Fort Lauderdale family-office restructurings using offshore yacht-holding companies and family-limited partnerships sometimes trip this wire.

Nominee and alter-ego liens

The IRS files a nominee or alter-ego lien when assets titled in another's name actually belong to the taxpayer. Common around Fort Lauderdale yacht-holding LLCs, single-member Caribbean charter entities, and condo-holding Florida LLCs used in pre-immigration and asset-protection planning.

FBAR willfulness exposure

Willful FBAR penalties under 31 USC §5321(a)(5)(C) can reach the greater of $100,000 or 50% of the highest account balance per year. The Supreme Court's Bittner v. United States (2023) decision limited non-willful penalties to per-form rather than per-account, but willful exposure remains severe. Fort Lauderdale yacht-LLC and Caribbean depositary cases generate steady willfulness questions.

Estate planning and IRC §6013 joint filing

Wilton Manors and Fort Lauderdale joint-filer households post-Obergefell file federally under IRC §6013(a) and qualify for unified-credit portability under IRC §2010(c)(5). Estate planning for high-net-worth Broward couples often layers spousal lifetime-access trusts, charitable lead annuity trusts, and grantor-retained annuity trusts — each with its own federal reporting consequences and audit profile.

Estate and decedent returns

A decedent's final Form 1040 and the estate's Form 1041 are the executor's responsibility. Personal liability for the executor attaches under 31 USC §3713(b) if distributions are made before federal tax claims are satisfied — a frequent problem in Broward probate where yacht assets, international holdings, and trust structures complicate Form 706 valuation.

What resolution can look like for a Fort Lauderdale file

Debt reduced

An accepted Offer in Compromise settles the federal liability for less than the full amount. Partial Pay IAs cap recovery at what you can pay through the CSED. Currently Not Collectible status freezes federal collection while you stabilize income. Streamlined Filing eliminates civil penalties on non-willful offshore disclosures.

Penalties abated

First-Time Penalty Abatement removes failure-to-file and failure-to-pay penalties for a clean compliance year. Reasonable-cause requests handle hurricane-disaster periods, serious illness, and preparer reliance. Form 8938 and FBAR penalty mitigation argued under IRS Penalty Mitigation Guidelines.

Liens and levies released

An NFTL withdraws once a streamlined IA is in place under Fresh Start. Wage and bank levies release when the underlying account moves to CNC, IA, or OIC. Passport certifications reverse once the debt drops below the IRC §7345 threshold.

Outcomes vary. Past results do not guarantee future outcomes. Each tax case is unique.

Settlement ranges from the firm's case files

The following ranges come from Victory Tax Lawyers cases over the past several years and contribute to the firm's $100M+ aggregate federal tax-relief figure. Names and identifying facts are removed for confidentiality. Each file's actual posture differed on asset position, monthly disposable income, and IRS examiner discretion.

Matter type Original liability Resolution Approximate result
Installment Agreement $138,420 IRC §6159 streamlined IA $25/month accepted
Partial Pay IA $116,275 IRC §6159 PPIA through CSED $50/month accepted
Streamlined Domestic Offshore $94,108 SDO submission, 5% misc. penalty Accepted, civil FBAR penalty avoided
Partial Pay IA $122,640 IRC §6159 PPIA through CSED $50/month accepted
Installment Agreement $154,892 IRC §6159 streamlined IA $25/month accepted

Past results do not guarantee future outcomes. Each tax case is unique and turns on facts, asset position, monthly disposable income, IRS Allowable Living Expense tables, and the discretion of the assigned Revenue Officer or Settlement Officer. Acceptance rates for Offer in Compromise vary widely — the IRS reported a nationwide acceptance rate of roughly 30 to 40 percent in recent years. Streamlined Filing Compliance Procedures acceptance is high when the facts support non-willfulness.

Why a California-licensed firm represents Fort Lauderdale taxpayers

Federal tax practice is regulated by the Treasury Department under 31 CFR Part 10 (Circular 230). An attorney admitted in any U.S. jurisdiction may represent any taxpayer before the IRS in any state via Form 2848 Power of Attorney. State-bar admission is a state-court question; the IRS is a federal agency, the U.S. Tax Court is a federal court of national jurisdiction, and the IRS Independent Office of Appeals is a federal administrative venue.

Parham Khorsandi is a member of the State Bar of California (license #266658) and is admitted to practice before the United States Tax Court — admission to that court is national, not state-bound, so it covers Miami Tax Court sessions assigned to Broward petitioners identically to Los Angeles sessions. Amir Boroumand (Cal Bar #269570) supplements the firm's federal-practice capacity. Both attorneys are subject to the State Bar of California's professional-conduct rules, including Rule 7.1 on advertising accuracy and Rule 1.6 on confidentiality.

The workflow runs entirely remote through a secure client portal, with encrypted file exchange and scheduled video calls. Fort Lauderdale clients have not needed to drive to an office for a federal case in years; the same is true for our Miami, Orlando, Tampa, and Jacksonville work. Form 2848 routes all IRS notices to our office. The IRS communicates with us in writing; we communicate with you through the portal — an important point for Broward filers whose schedules pivot around Boat Show season, cruise rotations at Port Everglades, and Caribbean travel.

Where a matter truly requires an attorney admitted in Florida — a Florida Division of Administrative Hearings (DOAH) sales-tax contest that proceeds to a Florida circuit court for judicial review, a Florida probate matter involving estate-tax controversies, or a state-court receivership for a defunct Fort Lauderdale operating company — we coordinate with Florida counsel and remain engaged on the federal posture. Most VTL Fort Lauderdale cases are pure federal practice and do not require Florida-bar representation at all. We will tell you in the free consultation which category your file falls into.

The seven steps of a VTL tax-resolution engagement

1

Free consultation

A 30-minute call with an attorney to outline the facts, the IRS notices received, and the realistic resolution options for your Fort Lauderdale file.

2

Engagement letter

A written attorney-client agreement defines scope, fee, and authority. Federal common-law attorney-client privilege attaches from this point forward.

3

Form 2848 filed

Power of Attorney filed with the IRS Centralized Authorization File so all subsequent IRS notices route to the firm and away from your Fort Lauderdale mailbox.

4

CAF investigation

Account Transcripts, Wage and Income Transcripts, and Record of Account pulled across all open tax years. CSED dates verified before any negotiation.

5

Strategy memo

A written analysis recommending OIC, IA, CNC, audit response, CDP, Streamlined Filing, Voluntary Disclosure, or Tax Court petition based on the financial profile we built from the transcripts.

6

Resolution filed

Forms 656, 433-A(OIC), 9423, 12153, Streamlined certifications, FBAR submissions, or a Tax Court Petition prepared and filed. Negotiations with Revenue Officers, Settlement Officers, or Appeals Officers handled directly by us.

7

Compliance close-out

Post-resolution monitoring: future quarterly estimates, FBAR filings, return filings, and protection against IA default. The case is not done when the offer is accepted — it is done when the new compliance pattern is stable.

Collection statute warning — federal and Florida

Under IRC §6502(a), the IRS generally has ten years from the date of assessment to collect a federal tax. After the Collection Statute Expiration Date, the debt becomes uncollectible by operation of law. Several events toll or extend the CSED, including a pending Offer in Compromise (extends by the OIC pendency plus 30 days), bankruptcy filing (extends by the bankruptcy stay plus six months), a Collection Due Process hearing (extends while pending), Innocent Spouse claims, and continuous absence from the United States for six months or more — relevant for Fort Lauderdale yacht crew on long international rotations and cruise officers homeported abroad under IRC §6503(c).

On the Florida state side, Florida has no state personal income tax, so there is no state CSED for individuals on income matters. Florida's 5.5% corporate income tax under Fla. Stat. Chapter 220 and sales-and-use tax under Chapter 212 carry their own assessment and collection windows: Fla. Stat. §95.091 generally limits the Florida DOR to three years for assessment, extended to six years on substantial underreporting and removed entirely on fraud or non-filing. Documentary Stamp Tax under Chapter 201 attaches at recording.

Federal disaster postponements under IRC §7508A from Hurricane Ian (FEMA-4673-DR-FL), Hurricane Idalia (FEMA-4734-DR-FL), Hurricane Helene (FEMA-4828-DR-FL), and Hurricane Milton (FEMA-4834-DR-FL) shifted statute-of-limitations dates for many Broward taxpayers. Pull the disaster-period chronology before assuming the SOL is what your software calculator says it is.

Before negotiating any federal resolution, pull your IRS Account Transcripts and verify your CSED dates. Submitting an OIC restarts an already-running clock; sometimes a Partial Pay Installment Agreement that runs out the statute is the better strategy than an offer that extends it. For FBAR matters, the FBAR statute of limitations under 31 USC §5321(b)(1) is six years from the date of the violation — longer than the income-tax SOL, and a separate calculation entirely.

Fort Lauderdale venue: where federal and state tax matters are heard

Federal tax matters affecting Fort Lauderdale taxpayers proceed in federal venues. State matters that reach litigation move through the Florida Division of Administrative Hearings (DOAH) and, on judicial review, the appropriate Florida circuit court.

U.S. Tax Court — Miami trial city for Broward petitioners

The United States Tax Court holds no permanent Fort Lauderdale session. Broward petitioners typically designate Miami as the place of trial under Tax Court Rule 140, with sessions held at the Wilkie D. Ferguson Jr. U.S. Courthouse, 400 N. Miami Avenue, Miami, FL 33128. Tampa is the alternate west-coast designation.

U.S. District Court — Southern District of Florida, Fort Lauderdale Division

Federal refund suits, civil tax-collection actions, and criminal-tax prosecutions for Broward defendants proceed in the U.S. District Court for the Southern District of Florida, Fort Lauderdale Division, U.S. Courthouse, 299 E. Broward Boulevard, Fort Lauderdale, FL 33301. Federal magistrate judges handle initial appearances and pretrial matters at the same courthouse.

IRS Taxpayer Assistance Center — Plantation

The IRS operates the Broward Taxpayer Assistance Center at 1248 N. University Drive, Plantation, FL 33322, the closest TAC for Fort Lauderdale residents. Appointments are scheduled through the IRS office locator or 844-545-5640. We attend TAC appointments for clients under Form 2848 so you do not have to.

Florida Department of Revenue — Fort Lauderdale Service Center

The Florida Department of Revenue administers state corporate income tax, sales-and-use tax, Documentary Stamp Tax, and reemployment tax from its main office at 5050 W. Tennessee Street, Tallahassee, FL 32399, with a Fort Lauderdale Service Center at 1400 W. Commercial Boulevard, Suite 145, Fort Lauderdale, FL 33309 for in-person audit conferences when remote is not workable.

Broward County Records, Taxes and Treasury

The Broward County Records, Taxes and Treasury Division, 115 S. Andrews Avenue, Room A-100, Fort Lauderdale, FL 33301, administers county property tax collection, tourist development tax, motor-vehicle registration, and county recording. NFTLs filed against Broward property are indexed here.

Broward County Property Appraiser

The Broward County Property Appraiser, 115 S. Andrews Avenue, Room 111, Fort Lauderdale, FL 33301, handles annual assessment, homestead-exemption administration, and Save Our Homes assessment-cap calculations under Article VII of the Florida Constitution.

City of Fort Lauderdale Finance Department

The City of Fort Lauderdale Finance Department, 100 N. Andrews Avenue, 6th Floor, Fort Lauderdale, FL 33301, handles municipal business tax receipts, special assessments, and other city-level revenue. City matters are administrative, not adjudicatory, so a tax-controversy attorney is rarely needed here.

Florida Division of Administrative Hearings (DOAH)

The Florida Division of Administrative Hearings hears state-tax assessment protests referred by the Florida DOR under Fla. Stat. Chapter 120. DOAH proceedings are typically held in Tallahassee but can be conducted remotely or in regional locations. Decisions are subject to judicial review in Florida circuit court — an attorney admitted to the Florida Bar is required at that judicial-review stage, which is where we refer to local Florida counsel.

Request a free consultation with a Fort Lauderdale tax attorney

A 30-minute call with an attorney costs nothing. Bring your most recent IRS notice, your last filed return, any FBAR or Form 8938 history, and any Florida DOR correspondence. We will tell you which resolution options actually fit your Fort Lauderdale file before you sign anything — and whether your matter is pure federal or whether you also need Florida counsel for a state-court piece.

Frequently asked questions for Fort Lauderdale taxpayers

Reviewed by

Parham Khorsandi, Esq.

Parham Khorsandi, Esq.

Managing Attorney · California Bar #266658 · Admitted to the United States Tax Court

Parham Khorsandi is the managing attorney of Victory Tax Lawyers, LLP. His practice focuses on federal tax controversy — Offer in Compromise negotiations, Installment Agreements, FBAR and Streamlined Filing Compliance, Trust Fund Recovery Penalty defense, audit representation before the IRS Examination function, and litigation before the U.S. Tax Court. He has represented Fort Lauderdale and South Florida taxpayers across the yacht-industry, cruise, corporate-HQ (AutoNation and Citrix-successor), healthcare 1099, and Wilton Manors LGBT+ estate-planning segments in federal IRS matters, including U.S. Tax Court petitions calendared for Broward petitioners in Miami and Tampa.

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Attorney Advertising. Victory Tax Lawyers, LLP is a California-licensed law firm with its principal office at 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Information on this page is general in nature, may not reflect the most recent legal developments, and does not create an attorney-client relationship. This page is not legal advice. Federal tax outcomes depend on individual facts and Internal Revenue Service discretion. Past results do not guarantee future outcomes; each tax matter is unique.

IRS Circular 230 Disclosure. To ensure compliance with requirements imposed by the IRS, any U.S. federal tax advice contained on this page is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.

Fort Lauderdale / Florida-specific note. VTL attorneys are licensed in California. Federal IRS, FBAR, and U.S. Tax Court representation is provided to Fort Lauderdale and Broward County residents under Form 2848 Power of Attorney and U.S. Tax Court bar admission, which are recognized in all 50 states. Florida Department of Revenue matters are handled remotely under Form DR-835 (Florida Power of Attorney). State-court matters requiring Florida-Bar admission — including judicial review of Florida DOR sales-tax determinations in Florida circuit court and Florida probate or receivership matters — are referred to local Florida counsel. Consult a licensed attorney about your specific situation before acting on any content on this page.