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Tax Attorney in Harrisburg, PA

Federal IRS representation for Harrisburg individuals and businesses — audits, back taxes, liens, levies, payroll-tax disputes, and U.S. Tax Court litigation at the Ronald Reagan Federal Building and Courthouse, 228 Walnut Street. As the Pennsylvania state capital and the seat of the PA Department of Revenue, the PA Board of Finance and Revenue, and the PA Commonwealth Court, Harrisburg is the procedural heart of every Pennsylvania state-tax controversy — and we coordinate PA DOR matters here under Form REV-677 alongside the federal case.

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Serving Harrisburg, Dauphin County, Cumberland County, Hershey, Mechanicsburg, Carlisle, Middletown, Camp Hill, and the South Central Pennsylvania capital region

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

Pennsylvania carries a flat 3.07% personal income tax under 72 Pa.C.S. § 304 — one of the lowest flat rates in the country — and Harrisburg layers a 2% Local Earned Income Tax on resident wages under the Pennsylvania Local Tax Enabling Act (Act 32 of 2008), administered through the Capital Tax Collection Bureau (CapTax). A Harrisburg resident pays an effective combined state-plus-local rate of roughly 5.07% on wage income before federal tax even enters the picture. Pennsylvania also imposes an inheritance tax at 4.5% on transfers to lineal descendants, 12% on transfers to siblings, and 15% on transfers to non-relatives under 72 Pa.C.S. § 9116 — one of only six states that still levies a separate inheritance tax. Stack that on the 37% federal top rate and a Penn State-Hershey Medical Center physician, a TE Connectivity equity-vest year, a Hershey Company executive RSU release, or a state legislator with outside professional income can produce a six-figure tax exposure in a single year.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the Pennsylvania Department of Revenue has issued a Notice of Assessment with proposed tax, penalty, and interest from its Strawberry Square headquarters at 4th and Walnut Streets here in Harrisburg, the deadline to act is short. We pull your IRS account transcripts, calculate your CSED under IRC § 6502, file Form 2848 with the IRS and Form REV-677 with the PA DOR, and put administrative brakes on collection while the case is built.

Federal tax representation for Harrisburg 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 Harrisburg at the Ronald Reagan Federal Building and U.S. Courthouse, 228 Walnut Street. Harrisburg is the U.S. Tax Court trial city for the Middle District of Pennsylvania, drawing petitioners from Dauphin, Cumberland, York, Lancaster, Lebanon, Perry, Adams, Franklin, Schuylkill, Snyder, Mifflin, Juniata, Northumberland, Union, Centre, and the surrounding capital region counties. From our Robertson Boulevard office in Los Angeles, we represent Harrisburg residents and Pennsylvania-domiciled businesses in IRS audits, collection cases, Tax Court petitions, Offers in Compromise under IRC § 7122, Installment Agreements under IRC § 6159, lien discharges under IRC § 6325, levy releases under IRC § 6343, and Trust Fund Recovery Penalty defenses under IRC § 6672.

For Pennsylvania state tax matters — the flat 3.07% personal income tax under 72 Pa.C.S. § 304, the 8.99% corporate net income tax (phasing down to 4.99% by 2031) under 72 Pa.C.S. § 7401, the 4.5% / 12% / 15% Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116, the 6% state sales-and-use tax (no Dauphin County local add-on, so Harrisburg's combined sales rate is 6%) under 72 Pa.C.S. § 7202, withholding-tax assessments, or contested matters headed to the Pennsylvania Board of Finance and Revenue — we file PA Form REV-677 with the Department of Revenue and handle the administrative track directly. There is a procedural advantage to a Harrisburg case the rest of Pennsylvania does not get: the PA DOR is headquartered four blocks from your house, the Board of Finance and Revenue sits ten blocks south at 1101 South Front Street, and the Commonwealth Court is up Capitol Hill at 601 Commonwealth Avenue. Every state tax authority a Pennsylvania taxpayer can encounter has its head office inside Harrisburg city limits. For formal litigation before the Pennsylvania Commonwealth Court or the Pennsylvania Supreme Court, we refer to locally admitted Pennsylvania counsel under a co-counsel arrangement. The federal layer is where most Penn State-Hershey physician, Hershey Company executive, TE Connectivity engineer, and state-government 1099 cases live, and that is where our engagement carries the load.

Harrisburg sits at the center of a South Central Pennsylvania economy unlike any other in the Commonwealth: the city is the seat of Pennsylvania state government, with the Pennsylvania General Assembly meeting in the State Capitol at 501 North 3rd Street, the Governor's executive offices, all 16 cabinet-level departments, the Pennsylvania Treasury, the Pennsylvania State Employees' Retirement System (SERS), the Public School Employees' Retirement System (PSERS), and tens of thousands of state employees, legislative staff, and 1099 lobbyist and consultant contractors. The capital region also anchors a heavy private-sector cluster: The Hershey Company corporate headquarters in Hershey (12 miles east) and the Hershey Trust Company — whose Milton Hershey School endowment is the largest pre-college K-12 endowment in the United States — TE Connectivity (the former Tyco Electronics, headquartered in Berwyn but with major Harrisburg-region engineering and manufacturing operations), UPMC Pinnacle in downtown Harrisburg, Penn State Health Milton S. Hershey Medical Center in Hershey, Holy Spirit (Geisinger) in Camp Hill, Penn State Harrisburg in Middletown, Messiah University in Mechanicsburg, Dickinson Law in Carlisle (15 miles west), and Harrisburg Area Community College. Add the Harrisburg Air National Guard Base at Harrisburg International Airport in Middletown, the legacy Three Mile Island nuclear site (Unit 1 closed 2019, with a planned 2028 restart announced by Constellation Energy), and a rapidly growing Bhutanese-Nepali refugee, Burmese, African, and Latino population on the south and east sides of the city, and the tax-resolution footprint covers high-W-2 state-government and legislative-staff cases, 1099 lobbyist and consultant underwithholding, RSU compensation at Hershey and TE Connectivity, § 1202 Qualified Small Business Stock for capital-region biotech and AgTech ventures, § 6672 Trust Fund Recovery Penalty exposure for small Cumberland and Dauphin County employers, and steady FinCEN Form 114 work on overseas family accounts. The federal procedures are uniform; the facts are Harrisburg-specific.

Your tax rights as a Harrisburg taxpayer

Two parallel rights frameworks apply when you owe tax. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from the Pennsylvania Consolidated Statutes Title 72, the Department of Revenue's Taxpayer Rights Advocate office (whose headquarters sits at Strawberry Square, four blocks from the State Capitol), and the procedural rules of the Pennsylvania Board of Finance and Revenue at 1101 South Front Street. Knowing both is the difference between a clean resolution and a missed 60-day Board of Finance and Revenue petition window that locks in a state assessment against your Uptown Harrisburg, Riverside, Bellevue Park, Hershey, or Camp Hill property.

Right to representation

IRC § 7521(b)(2) and (c) give you the right to be represented by an attorney, CPA, or Enrolled Agent during any IRS examination or interview. Once Form 2848 is on file, the IRS must deal with us first, not you. Pennsylvania mirrors this through PA Form REV-677 Power of Attorney, accepted for all Department of Revenue matters at Strawberry Square.

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 Harrisburg at the Ronald Reagan Federal Building and U.S. Courthouse, 228 Walnut Street — the Middle District of Pennsylvania trial city.

Right to PA Board of Finance and Revenue review

72 Pa.C.S. § 9702 and the Board's procedural rules give you 60 days from a final PA Department of Revenue Board of Appeals decision to file a petition with the Pennsylvania Board of Finance and Revenue at 1101 South Front Street, Suite 400, Harrisburg PA 17104 — a ten-block walk from City Hall. The 60-day window is shorter than the federal 90-day Tax Court deadline. Missing it forfeits the right to administrative review of the state assessment before judicial appeal to the Pennsylvania Commonwealth Court.

Collection Due Process

IRC § 6320 (lien) and IRC § 6330 (levy) give you a 30-day window to request a CDP hearing once the IRS files a Notice of Federal Tax Lien or issues a Final Notice of Intent to Levy. A timely CDP filing halts collection and preserves judicial review through the U.S. Tax Court.

Right to settle for less than owed

Federally, IRC § 7122 authorizes Offers in Compromise based on doubt as to liability, doubt as to collectibility, or effective tax administration. Pennsylvania runs a Deferred Payment Plan program and a more selective Compromise program under 72 Pa.C.S. § 9707 administered by the PA DOR, with hardship and insolvency standards similar to but tighter than the federal framework. Both programs require all returns filed and current-year compliance before consideration.

Right to recover fees

IRC § 7430 allows recovery of administrative and litigation costs if the IRS takes a position that is not substantially justified and the taxpayer prevails. The threshold is high, but real, especially in audit reconsideration and Innocent Spouse cases under IRC § 6015.

How Victory Tax Lawyers helps Harrisburg 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 Harrisburg taxpayers carrying a parallel Pennsylvania liability, we coordinate a PA Compromise petition under 72 Pa.C.S. § 9707 with the DOR at Strawberry Square on the same financial showing, sequencing the two programs so an accepted federal Offer does not break a pending state offer or vice versa.

Installment Agreements under IRC § 6159

Streamlined IAs (under $50,000), partial-pay IAs under IRC § 6159(d), and full-pay agreements. We push for partial-pay structures where the IRC § 6502 ten-year CSED will extinguish the balance before payoff — the most under-used resolution path for Harrisburg taxpayers carrying between $50,000 and $250,000 in federal debt, particularly Penn State-Hershey attending physicians who never made quarterly payments, retired state employees who took a lump-sum SERS distribution, TE Connectivity engineers with concentrated RSU vests, and Hershey Company executives who exercised options in a strong-stock year.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Harrisburg property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Dauphin County Recorder of Deeds at the Dauphin County Administration Building, 2 South Second Street, encumber title on Uptown, Midtown, Riverside, Bellevue Park, Camp Hill, Mechanicsburg, Hershey, Hummelstown, and Carlisle properties; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing date.

Levy release under IRC § 6343

Wage levies, bank levies, and accounts-receivable levies. We document economic hardship under IRC § 6343(a)(1)(D) and Treasury Reg. § 301.6343-1(b)(4), and where the levy is procedurally defective, we challenge it through Collection Due Process or Appeals. Pennsylvania state tax liens follow a parallel track under 72 Pa.C.S. § 7805 and are recorded in the Prothonotary's office for the county where the taxpayer holds real property; in Harrisburg that is the Dauphin County Prothonotary at the Dauphin County Courthouse, 101 Market Street.

Audit defense and U.S. Tax Court litigation

Correspondence audits, office audits, and field examinations — including sensitive issues like cryptocurrency, foreign accounts under FinCEN Form 114 (FBAR), S-corporation reasonable-compensation, § 83(b) election validity, § 1202 Qualified Small Business Stock claims for capital-region biotech and AgTech spin-outs, § 174 R&D capitalization timing for engineering contractors serving TE Connectivity and Penn State-Hershey research labs, and § 107 minister's housing allowance for clergy across the capital region's many churches. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Harrisburg trial sessions are held at the Ronald Reagan Federal Building and U.S. Courthouse, 228 Walnut Street.

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. Pennsylvania penalties under 72 Pa.C.S. § 352 (failure to file) and § 353 (failure to pay) follow a separate reasonable-cause analysis applied by the PA DOR at Strawberry Square and reviewable by the Board of Appeals and then the Board of Finance and Revenue at 1101 South Front Street.

Twelve types of Harrisburg tax matters we handle

Federal cases for Harrisburg residents and businesses, framed against the PA DOR and Harrisburg local-tax overlay where it matters.

Pennsylvania state-employee SERS and PSERS retirement-distribution exposure

Harrisburg has the highest concentration of Pennsylvania state employees in the Commonwealth. A retiring SERS member or PSERS-covered teacher who elects a lump-sum or partial-lump-sum distribution rather than a monthly annuity triggers ordinary-income inclusion at the federal 22% to 37% marginal bracket plus the 3.07% Pennsylvania PIT and the 2% Harrisburg Local Earned Income Tax if still resident. A $400,000 SERS lump-sum can produce an $80,000 to $150,000 federal balance due the following April when supplemental withholding fell short. Direct rollover under IRC § 402(c) avoids the immediate income event; missed rollover windows are a routine resolution case.

Pennsylvania Inheritance Tax exposure

72 Pa.C.S. § 9116 imposes the Pennsylvania Inheritance Tax at 4.5% on transfers to lineal descendants (children, grandchildren), 12% on transfers to siblings, and 15% on transfers to nieces, nephews, and non-relatives. Pennsylvania is one of only six states still imposing a separate inheritance tax. Uptown, Riverside, Bellevue Park, Susquehanna Township, Camp Hill, Hershey, and Hummelstown estate values regularly cross the threshold where the 4.5% tax adds up to a meaningful number, particularly when sibling transfers (12%) or non-relative bequests (15%) come into play. Form REV-1500 is due within nine months of death and filed with the Dauphin County Register of Wills; a 5% discount is available for prepayment within three months.

Lobbyist and legislative-consultant 1099 underwithholding

As the seat of Pennsylvania state government, Harrisburg supports a substantial registered-lobbyist and political-consultant population. Form 1099-NEC income from PA Department of State-registered lobbying firms, association contracts, and campaign-finance work hits Schedule C with 15.3% SECA self-employment tax under IRC § 1401 layered on top of the federal marginal rate, 3.07% Pennsylvania, and 2% Harrisburg LEIT. Without quarterly Form 1040-ES payments, the first IRS CP14 lands the spring after a strong legislative session.

Penn State-Hershey 1099 physician income

Penn State Health Milton S. Hershey Medical Center in Hershey, UPMC Pinnacle in downtown Harrisburg, and Holy Spirit (Geisinger) in Camp Hill anchor the capital region's medical economy. Attending physicians, surgical specialists, anesthesiologists, and pathologists frequently carry side 1099 income from independent surgical centers, telemedicine, clinical-trial honoraria, and pharmaceutical-royalty arrangements. The federal Schedule C self-employment exposure plus 15.3% SECA under IRC § 1401, the Pennsylvania 3.07% PIT, and the Harrisburg 2% Local Earned Income Tax can land a Penn State-Hershey physician with a five- or six-figure balance due the spring after a strong year.

Hershey Company and TE Connectivity RSU vest events

The Hershey Company (NYSE: HSY) corporate headquarters in Hershey and TE Connectivity (NYSE: TEL, the former Tyco Electronics) operations across the capital region produce a steady population of mid-level and senior executives carrying significant Restricted Stock Unit vests. RSU vests are taxed as W-2 ordinary income at the supplemental wage withholding rate (22% federal on amounts up to $1 million per year, 37% above). An executive at the 35% or 37% marginal federal bracket is underwithheld by 13 to 15 percentage points on every vest, on top of the 3.07% Pennsylvania PIT and 2% Harrisburg LEIT shortfall — producing a $40,000 to $250,000+ April balance.

Notice of Federal Tax Lien

NFTLs filed with the Dauphin County Recorder of Deeds at the Dauphin County Administration Building, 2 South Second Street, encumber title and trigger CDP rights under IRC § 6320. A parallel Pennsylvania state tax lien may be recorded under 72 Pa.C.S. § 7805 in the Prothonotary's office for the county where the taxpayer holds real property. Uptown, Midtown, Riverside, Camp Hill, Mechanicsburg, Hershey, and Hummelstown closings stall fast when an NFTL hits the title search.

IRS bank or wage levy

Bank levies on accounts held at Members 1st Federal Credit Union (Mechanicsburg-headquartered, the largest credit union in Central Pennsylvania), Mid Penn Bank, Centric Bank, Riverview Bank, Orrstown Bank, M&T Bank (Harrisburg operations), PNC, Citizens, F&M Trust (Chambersburg, with Harrisburg branches), or any Pennsylvania-chartered institution. Wage levies hit Harrisburg employers within days of CP90 or LT11 issuance — including the Commonwealth of Pennsylvania (state-employee payroll), Penn State Health, UPMC Pinnacle, The Hershey Company, TE Connectivity, Highmark Health, Penn State Harrisburg, Messiah University, Harrisburg Area Community College, and the Pennsylvania House and Senate caucus payrolls.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. With Harrisburg International Airport (MDT) serving regional and limited international routes, a Penn State-Hershey international-faculty population, a steady Bhutanese-Nepali refugee community with travel back to family in Nepal and Bhutan, and a growing African and Burmese refugee population on the south and east sides, this lands hard. We file the IRC § 7345(e) action to reverse the certification.

FBAR and FATCA non-disclosure

FinCEN Form 114 for foreign accounts over $10,000 aggregate. Harrisburg's Bhutanese-Nepali refugee community (one of the largest in the United States), Burmese refugee population, African (Liberian, Nigerian, Sudanese, Somali) immigrant population, and Latino (Puerto Rican, Dominican, Mexican) population all carry steady FBAR exposure on remittance accounts and inherited family accounts overseas. The IRS Streamlined Filing Compliance Procedures are a frequent engagement. ITIN applications under IRS Form W-7 routinely accompany the work for spouses and dependents without Social Security numbers.

Harrisburg Local Earned Income Tax disputes

The Pennsylvania Local Tax Enabling Act (Act 32 of 2008) consolidated local earned-income-tax collection into 69 Tax Collection Districts statewide. Harrisburg imposes a 2% LEIT on resident wages (1% to the City of Harrisburg and 1% to the Harrisburg School District), administered by the Capital Tax Collection Bureau (CapTax) at 506 South 32nd Street, Camp Hill. Disputes over residency (City of Harrisburg vs. Susquehanna Township, Penbrook Borough vs. Harrisburg, Steelton Borough vs. Harrisburg), reciprocal-credit calculations for residents working in non-PA states, and remote-work allocations since 2020 are a recurring assessment driver.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Harrisburg's small-business landscape — restaurants and bars across Midtown, Second Street, and the Broad Street Market district; construction firms across Dauphin and Cumberland counties; healthcare staffing companies tied to Penn State-Hershey and UPMC Pinnacle; lobbying-firm general partners; and small manufacturing operations in the South Hanover and Steelton corridor — produces a steady caseload. The IRS uses Form 4180 interviews to identify responsible persons. Pennsylvania applies a parallel responsible-person rule to withheld state income tax and sales tax under 72 Pa.C.S. § 7240.

Cryptocurrency tax assessments

CP2000 notices on unreported digital-asset gains, basis-tracking failures, and DeFi-protocol income. Capital-region tech-adjacent workers at TE Connectivity, state-government IT contractors, Penn State Harrisburg engineering students and alumni, and Hershey Company digital-marketing teams picked up substantial crypto exposure through 2021-2024. Form 1099-DA reporting (effective 2025) drives the matching cases. Pennsylvania treats virtual-currency gains as taxable under the 3.07% flat PIT and reportable on the Schedule D of PA-40, with no preferential capital-gain rate at the state level.

Nine common causes of tax debt for Harrisburg taxpayers

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

1. State-employee SERS or PSERS lump-sum distribution

A retiring Pennsylvania state employee or PSERS-covered teacher takes a lump-sum or partial-lump-sum distribution. The withholding at the 20% mandatory federal rate falls short of the actual 24% to 37% marginal bracket. Pennsylvania exempts most qualified retirement distributions from state PIT, but the federal balance due in April can be enormous.

2. RSU and ISO vest events at Hershey or TE Connectivity

A Hershey Company, TE Connectivity, or Highmark executive at the 35% or 37% federal marginal bracket sees only 22% supplemental withholding on RSU vests. The shortfall, plus 3.07% Pennsylvania and the 2% Harrisburg resident Local Earned Income Tax, produces a five- or six-figure balance due the following April.

3. Self-employment underpayment

Penn State-Hershey attending physicians with private 1099 practices, UPMC Pinnacle specialists, Penn State Harrisburg and Dickinson Law adjunct faculty, registered lobbyists, political consultants, real-estate agents, and Cumberland County tradespeople file Schedule C or K-1 income with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654.

4. Business closure

When an LLC, S-corp, or capital-region small business closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Restaurant and hospitality closures across Midtown, Second Street, and Hershey are a recurring source.

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 physician marriages, dual-state-employee households, and Hershey or TE Connectivity dual-equity couples.

6. Identity theft and fraudulent returns

A return filed in your name with refund redirected. Form 14039 opens the IRS identity-theft case; the assessment must be corrected, not just protested. Pennsylvania has its own DOR identity-theft and Fraud Investigation Unit that runs in parallel at Strawberry Square.

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. Pennsylvania mirrors the federal three-year refund bar under 72 Pa.C.S. § 346.

8. Real-estate sale without estimated tax

A Uptown, Bellevue Park, Hershey, or Hummelstown sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Pennsylvania taxes the gain at the flat 3.07% rate with no separate capital-gain category. Harrisburg resident sellers also owe the 2% Local Earned Income Tax on the gain only if it is characterized as earned income (typically dealer-status under IRC § 1221), not investment income.

9. Stock-option exercise without planning

ISO disqualifying dispositions and NSO ordinary-income inclusions hit Hershey Company, TE Connectivity, and Highmark equity-holders with AMT under IRC § 55 and large balances due. IRC § 83(b) elections missed within the 30-day window create their own irreversible problem — especially costly for capital-region biotech and AgTech founders whose early-grant basis was low.

Eight tax liabilities that pull in Harrisburg taxpayers

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

Failure to file federal return

IRC § 6651(a)(1) imposes 5% per month, capped at 25%, plus interest under IRC § 6601. The Pennsylvania mirror is 72 Pa.C.S. § 352 imposing a 5% per month late-filing penalty (minimum $5, capped at 25%) on unpaid Pennsylvania tax.

Failure to file Pennsylvania return

72 Pa.C.S. § 352 imposes a 5% per month penalty on the unpaid tax for failure to file, capped at 25%, plus interest under 72 Pa.C.S. § 806. The PA DOR at Strawberry Square may issue a Notice of Assessment triggering an internal Board of Appeals window, with further review by the Pennsylvania Board of Finance and Revenue under 72 Pa.C.S. § 9702 within 60 days of the Board of Appeals decision.

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.

Pennsylvania sales-tax delinquency

72 Pa.C.S. § 7202 sets the 6% state sales tax on retail sales of tangible personal property and certain enumerated services. Dauphin County adds no local sales tax, so Harrisburg's combined rate stays at 6% — lower than Pittsburgh (7%) and Philadelphia (8%). 72 Pa.C.S. § 7240 imposes personal liability on responsible persons for unpaid trust-fund sales tax. The Pennsylvania use tax under 72 Pa.C.S. § 7202 is aggressively enforced against businesses purchasing equipment out of state.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Pennsylvania applies a parallel responsible-person rule to withheld state income tax and sales tax under 72 Pa.C.S. § 7240. Harrisburg's small-business, restaurant, lobbying-firm, and healthcare-staffing operators see this assessment routinely.

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. 72 Pa.C.S. § 353 imposes a parallel underpayment penalty at the state level.

Pennsylvania Inheritance Tax

72 Pa.C.S. § 9116 imposes Pennsylvania Inheritance Tax at 4.5% on transfers to lineal descendants, 12% on transfers to siblings, and 15% on transfers to non-relatives. Pennsylvania is one of only six states that still imposes a separate inheritance tax. Form REV-1500 is filed with the Pennsylvania Register of Wills (in Harrisburg that is the Dauphin County Register of Wills at the Dauphin County Courthouse, 101 Market Street) within nine months of death; a 5% discount is available for prepayment within three months of death.

Transferee liability

IRC § 6901 lets the IRS pursue a transferee — a person who received property from a delinquent taxpayer — for the transferor's unpaid tax, up to the value of the transferred property.

What resolution can look like

Debt reduced

An accepted IRC § 7122 Offer in Compromise can resolve six-figure balances for cents on the dollar where Reasonable Collection Potential supports the offer. The acceptance rate sits around 33% nationally; preparation determines the outcome.

Penalties abated

First-Time Abate removes a single year of failure-to-file or failure-to-pay penalties for taxpayers with a clean three-year compliance record. Reasonable-cause abatement under IRM 20.1.1 reaches further when supported by documentation.

Lien released or withdrawn

Once a debt is paid in full, the IRS releases the Notice of Federal Tax Lien within 30 days per IRC § 6325(a). On an Installment Agreement of $25,000 or less, lien withdrawal under Form 12277 can be requested to clear title with the Dauphin County Recorder of Deeds.

Sample tax-resolution outcomes

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

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

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

Why Victory Tax Lawyers for a Harrisburg federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Pennsylvania-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 Harrisburg at the Ronald Reagan Federal Building and U.S. Courthouse, 228 Walnut Street. 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 Harrisburg clients never need a separately admitted Pennsylvania attorney because the case is, at its core, federal.

For administrative work before the Pennsylvania Department of Revenue at Strawberry Square — protests, audit responses, Compromise petitions under 72 Pa.C.S. § 9707, and Deferred Payment Plan requests — we file PA Form REV-677 Power of Attorney and handle the matter remotely. When a case must move to the Pennsylvania Board of Finance and Revenue (the state administrative tribunal at 1101 South Front Street, Suite 400, Harrisburg) or appeal further to the Pennsylvania Commonwealth Court (the intermediate appellate court that hears tax appeals from the Board of Finance and Revenue, sitting at 601 Commonwealth Avenue, Suite 2100, Harrisburg) or the Pennsylvania Supreme Court, we coordinate with locally admitted Pennsylvania counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the bigger exposure given Penn State-Hershey 1099 physician income, Hershey Company and TE Connectivity RSU vests, state-employee SERS and PSERS lump-sum distributions, and lobbyist 1099 underwithholding, 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 Pennsylvania-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Harrisburg 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 Harrisburg clients

1

Free consultation

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

2

Engagement letter

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

3

Form 2848 and CAF

We file the federal Power of Attorney with the IRS and PA Form REV-677 with the Pennsylvania DOR at Strawberry Square, register on the CAF system, and step in as the contact of record.

4

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events.

5

Strategy memo

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

6

Filing and negotiation

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

7

Compliance monitoring

After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, and prevent default.

Two collection clocks: federal CSED and Pennsylvania's 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.

Pennsylvania runs a parallel state collection rule under 72 Pa.C.S. § 7805. The PA DOR generally must assess Pennsylvania personal income tax within three years of the return due date (extended for substantial omissions, with no statute on collection in cases of fraud or non-filing). Once a state tax lien is recorded in the Dauphin County Prothonotary's office at the Dauphin County Courthouse, 101 Market Street, it remains effective until satisfied and is renewable under PA law. Many Harrisburg taxpayers carry a federal CSED that will run out before the Pennsylvania state-lien clock — or vice versa. Pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.

Harrisburg tax authorities and venues

Harrisburg is unusual among American cities — as the Pennsylvania state capital, every state-level tax authority a Pennsylvania taxpayer can encounter has its head office within walking distance of City Hall. A working knowledge of the tribunals, agencies, and field offices in Harrisburg is what separates an answered Notice from a wage levy. Below is the working list our firm uses on every Harrisburg matter.

Internal Revenue Service — Harrisburg TAC

The federal tax authority, at irs.gov. The Harrisburg Taxpayer Assistance Center operates at the Ronald Reagan Federal Building, 228 Walnut Street, Room 416, Harrisburg PA 17101. Appointments required.

U.S. Tax Court — Harrisburg trial sessions

The U.S. Tax Court holds regular trial sessions in Harrisburg at the Ronald Reagan Federal Building and U.S. Courthouse, 228 Walnut Street, Harrisburg PA 17101. Harrisburg is the Middle District of Pennsylvania trial city, drawing petitioners from Dauphin, Cumberland, York, Lancaster, Lebanon, Perry, Adams, Franklin, Schuylkill, Snyder, Mifflin, Juniata, Northumberland, Union, Centre, and surrounding counties. Petitions are filed at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

Pennsylvania Department of Revenue — HQ

The state tax authority, at revenue.pa.gov. Headquartered at Strawberry Square, 4th & Walnut Streets, Harrisburg PA 17128 — four blocks from the State Capitol. Administers the flat 3.07% personal income tax under 72 Pa.C.S. § 304, the 8.99% corporate net income tax (phasing down) under 72 Pa.C.S. § 7401, the 6% state sales-and-use tax under 72 Pa.C.S. § 7202, withholding tax, and the Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116. Harrisburg taxpayers walk into the same building where every PA tax assessment is generated.

Pennsylvania Board of Finance and Revenue — HQ

The state administrative tax appeals tribunal. Seated at 1101 South Front Street, Suite 400, Harrisburg PA 17104 — the only state-tax tribunal headquartered in Harrisburg, a procedural advantage no other Pennsylvania city has. Hears second-level appeals from final decisions of the PA DOR Board of Appeals on personal income tax, corporate net income tax, sales and use tax, employer withholding, and inheritance tax. 60-day petition deadline under 72 Pa.C.S. § 9702 from the Board of Appeals decision. Further appeal lies to the Pennsylvania Commonwealth Court.

Pennsylvania Commonwealth Court — HQ

The Commonwealth's intermediate appellate court with original and appellate jurisdiction over Pennsylvania tax appeals. Headquartered at 601 Commonwealth Avenue, Suite 2100, Harrisburg PA 17120, with hearings also held in Pittsburgh and Philadelphia. Appeals from the Board of Finance and Revenue are filed here under 42 Pa.C.S. § 763. Further appeal lies to the Pennsylvania Supreme Court. Victory Tax Lawyers refers Commonwealth Court litigation to locally admitted Pennsylvania counsel; we handle the federal portion and the PA DOR administrative work directly.

Pennsylvania State Capitol

The seat of the Pennsylvania General Assembly, at 501 North 3rd Street, Harrisburg PA 17120. The legislative source of every tax statute we cite on this page — 72 Pa.C.S. (Title 72 of the Pennsylvania Consolidated Statutes), 42 Pa.C.S. § 763 (Commonwealth Court jurisdiction), and Act 32 of 2008 (the Local Tax Enabling Act consolidating local earned-income-tax collection). Pennsylvania General Assembly session schedules drive per-diem income reporting for legislators and their staff.

City of Harrisburg Treasurer

The municipal finance authority for the City of Harrisburg. Office at 10 North 2nd Street, Harrisburg PA 17101. Administers Harrisburg real-estate tax collection, the Harrisburg business privilege and mercantile tax, and the City portion of the Harrisburg Local Earned Income Tax under Act 32 of 2008.

Dauphin County Treasurer

The county tax-collection authority. Office at 1 South Second Street, 5th Floor, Harrisburg PA 17101. Page: dauphincounty.gov. Administers Dauphin County real-estate tax collection, hotel-room rental tax, and county-level tax billing. The state 6% sales tax applies in Dauphin County with no local add-on.

Dauphin County Assessment

The county assessment authority. Office at 1 South Second Street, 6th Floor, Harrisburg PA 17101. Administers real-property assessments across Dauphin County, the Homestead Exclusion, and the Senior Citizen Tax Relief program. Property-tax assessment appeals run to the Dauphin County Board of Assessment Appeals and then to the Dauphin County Court of Common Pleas Civil Division.

U.S. District Court — Middle District of Pennsylvania, Harrisburg 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 (M.D. Pa., Harrisburg Division), located at the Ronald Reagan Federal Building and U.S. Courthouse, 228 Walnut Street, Harrisburg PA 17101, or the U.S. Court of Federal Claims in Washington, D.C.

IRS Independent Office of Appeals

The administrative-appeals body within the IRS that resolves cases without litigation. Harrisburg cases run through the Appeals offices serving the mid-Atlantic region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Capital Tax Collection Bureau (CapTax)

The designated Act 32 Tax Collection District administrator for the Capital Tax Collection District (covering Dauphin and a portion of Cumberland counties). Office at 506 South 32nd Street, Camp Hill PA 17011. Administers the Harrisburg 2% Local Earned Income Tax (1% to the City, 1% to the Harrisburg School District), residency determinations, and reciprocal-credit adjudications for residents working in non-PA states.

Speak with a tax attorney about your Harrisburg matter

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

Frequently asked questions — Harrisburg tax

What is the Harrisburg Local Earned Income Tax and how is it different from PA state tax?

The Harrisburg Local Earned Income Tax is a 2% wage tax on residents of the City of Harrisburg under the Pennsylvania Local Tax Enabling Act (Act 32 of 2008) — 1% to the City of Harrisburg and 1% to the Harrisburg School District. Non-residents who work in Harrisburg pay a 1% non-resident LST on wages earned in the City. This sits on top of, not in place of, the Pennsylvania state personal income tax of 3.07% under 72 Pa.C.S. § 304. A Harrisburg resident pays roughly 5.07% combined on every wage dollar before federal tax. The LEIT is administered by the Capital Tax Collection Bureau (CapTax) at 506 South 32nd Street, Camp Hill, the designated Act 32 collector for the Capital Tax Collection District covering Dauphin County and a portion of Cumberland County.

How does Pennsylvania Inheritance Tax work and who pays it?

The Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116 is paid on transfers at death from a Pennsylvania resident, or on Pennsylvania-situs real property and tangible personal property from a non-resident. Rates: 0% to a surviving spouse or a parent inheriting from a child under 21; 4.5% to lineal descendants and lineal ancestors (children, grandchildren, parents, grandparents); 12% to siblings; 15% to nieces, nephews, friends, and any other non-relative. Pennsylvania is one of only six states still imposing a separate inheritance tax. Form REV-1500 is filed with the Dauphin County Register of Wills at the Dauphin County Courthouse, 101 Market Street, within nine months of death. A 5% discount applies to tax paid within three months. Coordination with the federal estate-tax return on Form 706 is its own engagement layer when the gross estate is large enough to trigger federal filing.

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

The U.S. Tax Court holds regular trial sessions in Harrisburg itself at the Ronald Reagan Federal Building and U.S. Courthouse, 228 Walnut Street. Harrisburg is the U.S. Tax Court trial city for the Middle District of Pennsylvania — a Dauphin, Cumberland, York, Lancaster, Lebanon, Perry, Adams, Franklin, Schuylkill, or surrounding-county petitioner can request the Harrisburg trial location when filing the Tax Court petition. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline from the IRS Statutory Notice of Deficiency under IRC § 6213(a) is jurisdictional — a single day late and the federal assessment becomes final.

What is the Pennsylvania Board of Finance and Revenue and what is its deadline?

The Pennsylvania Board of Finance and Revenue is the state's administrative tax-appeals tribunal, headquartered at 1101 South Front Street, Suite 400, Harrisburg PA 17104 — a ten-block walk from City Hall and the only state-tax tribunal headquartered in any Pennsylvania city. It hears second-level appeals from final decisions of the PA Department of Revenue Board of Appeals on personal income tax, corporate net income tax, sales and use tax, employer withholding, and inheritance tax. The petition deadline is 60 days from the Board of Appeals decision under 72 Pa.C.S. § 9702 — tighter than the federal 90-day Tax Court deadline. Decisions are appealable to the Pennsylvania Commonwealth Court within 30 days under 42 Pa.C.S. § 763. Victory Tax Lawyers handles the administrative track through the Board of Appeals and the Board of Finance and Revenue under PA Form REV-677; we refer Commonwealth Court litigation to locally admitted Pennsylvania counsel.

I just retired from state government — how do my SERS or PSERS distributions get taxed?

Pennsylvania exempts most qualified retirement-plan distributions (including SERS and PSERS pension benefits) from the state 3.07% personal income tax under 72 Pa.C.S. § 301(d)(iii) — one of the most favorable state retirement-income rules in the country. The federal side is the entire story: a lump-sum or partial-lump-sum SERS distribution is ordinary income at the 22% to 37% federal marginal bracket. Mandatory federal withholding on an eligible-rollover distribution under IRC § 3405 is 20%, which often falls short of the actual marginal rate. The fix is either a direct rollover under IRC § 402(c) (no current tax), an annuity election (spreads income across years), or quarterly Form 1040-ES estimated-tax payments under IRC § 6654. Harrisburg-resident retirees still owe the 2% Local Earned Income Tax on earned-income components only — pension distributions themselves are not subject to the LEIT.

I am a Penn State-Hershey physician with side 1099 income — what should I expect?

Penn State Health Milton S. Hershey Medical Center attending physicians, surgical specialists, and clinical-faculty members frequently carry side 1099 income from independent surgical centers, second-opinion telemedicine, pharmaceutical clinical-trial honoraria, expert-witness work, and royalty arrangements on medical devices or patents. The 1099 income is reported on Schedule C and subject to 15.3% SECA self-employment tax under IRC § 1401 in addition to ordinary income tax at the 32% to 37% federal marginal rate, plus 3.07% Pennsylvania and 2% Harrisburg resident LEIT (if domiciled in the City of Harrisburg) or a different rate for Hershey, Hummelstown, or Derry Township residents. Without quarterly Form 1040-ES payments under IRC § 6654 and PA Form REV-414 estimates, a strong 1099 year produces a five- or six-figure balance the following April. Resolution paths include partial-pay Installment Agreements, S-corporation restructuring to control SECA, and reasonable-compensation analysis if the 1099 work is run through an LLC or PC.

What is Pennsylvania's collection statute of limitations?

72 Pa.C.S. § 346 gives the PA DOR three years from a return's due date to assess Pennsylvania personal income tax (extended for substantial omissions, with no limit for fraud or unfiled returns). Once an assessment is final, the DOR records a state tax lien under 72 Pa.C.S. § 7805 in the Prothonotary's office for the county where the taxpayer holds real property — in Harrisburg that is the Dauphin County Prothonotary at the Dauphin County Courthouse, 101 Market Street. The lien remains effective until satisfied and may be renewed by re-recording. The federal CSED under IRC § 6502 is a separate ten-year clock running from the federal assessment date. Coordinated case planning hinges on knowing both clocks before any action that could restart either one.

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

Yes. The IRS and the Pennsylvania Department of Revenue operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to Pennsylvania under the state's federal-change reporting rule (72 Pa.C.S. § 7330(b)), and vice versa. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the Pennsylvania return — and on the Harrisburg Local Earned Income Tax return administered by the Capital Tax Collection Bureau.

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

Yes, but it is narrower than the federal program. The Pennsylvania Department of Revenue at Strawberry Square operates a Compromise program under 72 Pa.C.S. § 9707 for personal income tax, corporate net income tax, sales and use tax, and other Pennsylvania taxes. The DOR considers compromises based on doubt as to collectibility or doubt as to liability — the third federal ground, effective tax administration, has no Pennsylvania analog. The PA DOR also operates a Deferred Payment Plan program for taxpayers who cannot pay in full but can pay over time. All Pennsylvania returns must be filed before consideration, and current-year compliance is verified. We typically run a state Compromise in parallel with the federal Offer where both debts are real.

I work at The Hershey Company or TE Connectivity and have RSUs — why did I owe so much tax this year?

RSU vest events are taxed as W-2 ordinary income at the supplemental wage withholding rate, which is currently 22% federal on amounts up to $1 million per year (37% above). If your actual marginal federal rate is 32%, 35%, or 37%, you are underwithheld by 10 to 15 percentage points on every vest. Add 3.07% Pennsylvania plus the 2% Harrisburg resident Local Earned Income Tax (if you live in the City of Harrisburg) or the applicable Derry Township, Hummelstown, or Hershey-area LEIT, and a single year of vesting can produce a $50,000 to $300,000+ balance due. The fix is W-4 adjustment plus quarterly Form 1040-ES under IRC § 6654 and Pennsylvania Form REV-414 estimates. Hershey Company corporate-headquarters, TE Connectivity engineering, and Highmark Health executives see this pattern every vest cycle.

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

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 Harrisburg. For Pennsylvania DOR administrative work at Strawberry Square, we file PA Form REV-677 Power of Attorney and handle the matter remotely through the Board of Appeals and the Board of Finance and Revenue. For formal litigation in the Pennsylvania Commonwealth Court or the Pennsylvania Supreme Court, we co-counsel with locally admitted Pennsylvania attorneys. Most engagements — audit defense, OIC, IA, levy release, Tax Court — are federal and stay entirely with our firm.

What if I have unfiled returns going back several years?

The IRS Voluntary Filing Compliance policy and IRM 5.1.11.6 generally require the last six years of returns to bring a taxpayer back into compliance. Filing prior-year returns is the first step before any OIC, IA, or CNC request — IRC § 7122(d) compliance is a prerequisite for a federal Offer. Refunds claimed on returns filed more than three years after the original due date are time-barred under IRC § 6511(b)(2). Pennsylvania follows a parallel filing-compliance posture; the DOR may assess based on federal-change reporting or estimate tax when a taxpayer fails to file. Harrisburg Local Earned Income Tax compliance with the Capital Tax Collection Bureau is a separate filing track for residents and non-resident workers.

Can the IRS levy my Harrisburg 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 Members 1st Federal Credit Union, Mid Penn Bank, Centric Bank, Riverview Bank, Orrstown Bank, M&T Bank, PNC, Citizens, F&M Trust, or any Pennsylvania-chartered institution and serve wage levies on Harrisburg employers including the Commonwealth of Pennsylvania state-employee payroll, Penn State Health, UPMC Pinnacle, The Hershey Company, TE Connectivity, Highmark Health, Penn State Harrisburg, Messiah University, and the Pennsylvania House and Senate caucus payrolls. 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). Pennsylvania issues parallel state tax liens under 72 Pa.C.S. § 7805 recorded in the Dauphin County Prothonotary's office.

A family member died in Pennsylvania — do I owe state inheritance tax?

Possibly yes. The Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116 has no exemption for non-spouse heirs — the tax applies from the first dollar. Rates are 0% to a surviving spouse, 4.5% to lineal descendants and ancestors (children, grandchildren, parents, grandparents), 12% to siblings, and 15% to nieces, nephews, and non-relatives. Pennsylvania is one of only six states still imposing a separate inheritance tax. An Uptown, Bellevue Park, Susquehanna Township, Camp Hill, Mechanicsburg, Hershey, or Hummelstown home plus retirement accounts and life-insurance proceeds payable to the estate can produce a meaningful inheritance-tax bill even for a child inheriting from a parent. Form REV-1500 is due nine months from death and is filed with the Dauphin County Register of Wills at the Dauphin County Courthouse, 101 Market Street. A 5% discount applies to tax paid within three months. 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 Pennsylvania Compromise petition under 72 Pa.C.S. § 9707 typically runs four to nine months on a parallel track.

Will hiring a tax attorney stop IRS collection action immediately?

Once Form 2848 is on file, the IRS routes all communication through the attorney and stops contacting the taxpayer directly. Active levies are not automatically lifted by the POA filing alone — release requires either a financial showing under IRC § 6343, a CDP filing under IRC § 6330, or an installment-agreement or OIC submission that triggers the IRC § 6331(k) collection bar. We move on those concurrently when a levy is in place. Pennsylvania state collection follows a similar pattern: a PA Form REV-677 routes DOR contact, and a pending Pennsylvania Compromise petition pauses state tax-lien enforcement.

About the author

This page was written and reviewed by Parham Khorsandi, Esq., Managing Attorney of Victory Tax Lawyers, LLP. Cal Bar #266658. Admitted to practice before the United States Tax Court. Mr. Khorsandi has resolved over 2,000 federal tax matters and secured more than $100 million in tax relief for clients across all 50 states.

Page last reviewed: . Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Pennsylvania statute citation references the Pennsylvania Consolidated Statutes Title 72. 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 Pennsylvania Department of Revenue, the U.S. Tax Court, the Pennsylvania Board of Finance and Revenue, the Pennsylvania Commonwealth Court, or other adjudicating body.

Victory Tax Lawyers, LLP is California-Bar-admitted with its principal office at 1100 S. Robertson Blvd., Los Angeles, CA 90035. The firm represents clients in federal tax matters nationwide via Form 2848 Power of Attorney and admission to the United States Tax Court. The firm is not admitted to practice in the courts of the Commonwealth of Pennsylvania; where a Pennsylvania state-court appearance or Pennsylvania Commonwealth Court tax litigation is required, the firm associates with locally admitted counsel.

IRS Circular 230 Disclosure: The discussion of U.S. federal tax issues on this page is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties imposed under the Internal Revenue Code or for promoting, marketing, or recommending to another party any tax-related matters addressed. For specific tax advice, consult independent tax counsel.

Authorities cited on this page

  • 26 U.S.C. § 7122 — Federal Offer in Compromise
  • 26 U.S.C. § 6159 — Installment Agreements
  • 26 U.S.C. § 6321 — Federal Tax Lien
  • 26 U.S.C. § 6325 — Lien Release and Discharge
  • 26 U.S.C. § 6331 — Levy and Distraint
  • 26 U.S.C. § 6343 — Release of Levy
  • 26 U.S.C. § 6502 — Collection Statute Expiration
  • 26 U.S.C. § 6213 — Tax Court Petition Window
  • 26 U.S.C. § 6320 — CDP for Liens
  • 26 U.S.C. § 6330 — CDP for Levies
  • 26 U.S.C. § 6651 — Failure-to-File and Failure-to-Pay
  • 26 U.S.C. § 6672 — Trust Fund Recovery Penalty
  • 26 U.S.C. § 6015 — Innocent Spouse Relief
  • 26 U.S.C. § 7345 — Passport Revocation
  • 26 U.S.C. § 402 — Qualified-Plan Distribution and Rollover
  • 26 U.S.C. § 3405 — Withholding on Pension and Annuity Payments
  • 26 U.S.C. § 107 — Minister's Housing Allowance
  • 26 U.S.C. § 1401 — Self-Employment Tax
  • 72 Pa.C.S. § 304 — Pennsylvania 3.07% personal income tax
  • 72 Pa.C.S. § 346 — Pennsylvania assessment statute of limitations
  • 72 Pa.C.S. § 352 — Pennsylvania failure-to-file penalty
  • 72 Pa.C.S. § 353 — Pennsylvania underpayment penalty
  • 72 Pa.C.S. § 7202 — Pennsylvania sales and use tax
  • 72 Pa.C.S. § 7240 — Pennsylvania responsible-person liability
  • 72 Pa.C.S. § 7330 — Pennsylvania federal-change reporting
  • 72 Pa.C.S. § 7401 — Pennsylvania corporate net income tax
  • 72 Pa.C.S. § 7805 — Pennsylvania state tax lien
  • 72 Pa.C.S. § 9116 — Pennsylvania Inheritance Tax
  • 72 Pa.C.S. § 9702 — PA Board of Finance and Revenue petition deadline
  • 72 Pa.C.S. § 9707 — Pennsylvania Compromise program
  • 42 Pa.C.S. § 763 — Pennsylvania Commonwealth Court tax jurisdiction
  • Act 32 of 2008 — Pennsylvania Local Tax Enabling Act (Harrisburg 2% Local Earned Income Tax)