Tax Attorney in Indianapolis, IN

Federal IRS representation for Indianapolis individuals and businesses — audits, back taxes, liens, levies, Eli Lilly RSU and ISO disputes, FedEx air-crew payroll, NCAA and Indy 500 driver 1099 work, and U.S. Tax Court litigation at the Birch Bayh Federal Building. We coordinate Indiana Department of Revenue matters under Form POA-1 Power of Attorney, and refer Indiana Tax Court litigation to locally admitted Indiana counsel under a co-counsel arrangement.

Reviewed by Parham Khorsandi, Esq. — California Bar #266658. Last reviewed: May 25, 2026.

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If you owe back taxes in Indianapolis, here is what shapes your 2026 case

Indiana keeps its 3.05% flat personal income tax under Ind. Code § 6-3-2-1, phasing down to 2.95% by 2026 under HEA 1002 and SB 451. On top of that flat state rate, Marion County imposes a County Local Income Tax of 2.02% under Ind. Code § 6-3.6 — administered by the Indiana Department of Revenue but pushing the effective Indianapolis state-and-local personal rate to 5.07%. Every one of Indiana's 92 counties layers its own CLIT on top of the state flat rate, which makes Indiana one of the few flat-rate states whose all-in tax burden varies materially by county of residence. Corporate income tax sits at 4.9% under Ind. Code § 6-3-2-1.5. State sales tax is 7% under Ind. Code § 6-2.5-2-2 with no local sales-tax add-on.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the Indiana DOR has issued a Proposed Assessment under Ind. Code § 6-8.1-5-1, the deadline to act is short. Indiana taxpayers get 60 days from a Letter of Findings to petition the Indiana Tax Court under Ind. Code § 6-8.1-9-1 — one of only a handful of U.S. states with a dedicated tax court of exclusive original jurisdiction. We pull your IRS account transcripts, calculate your CSED, file Form 2848 Power of Attorney with the IRS and Form POA-1 with the Indiana DOR, and put administrative brakes on collection while the case is built.

Federal tax representation for Indianapolis 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 Indianapolis at the Birch Bayh Federal Building, 46 E Ohio Street. From our Robertson Boulevard office in Los Angeles, we represent Indianapolis residents and Indiana-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 Indiana state tax matters — the 3.05% flat personal income tax (phasing to 2.95%), the 2.02% Marion County Local Income Tax under Ind. Code § 6-3.6, the 4.9% corporate income tax, the 7% state sales tax under Ind. Code § 6-2.5-2-2, withholding-tax assessments, and contested matters headed to the Indiana Tax Court — we file Form POA-1 with the Indiana Department of Revenue and handle the administrative track directly. For formal litigation in the Indiana Tax Court (a Tier-2 court established under Ind. Code 33-26 with exclusive original jurisdiction over DOR final determinations) or the Indiana state courts, we associate with locally admitted Indiana counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure for pharma RSU holders, FedEx air-cargo crew, and pro athletes, stays with us.

Indianapolis sits at the center of one of the most economically distinctive metros in the Midwest: Eli Lilly & Company headquarters in downtown Indianapolis, the dominant U.S. manufacturer of insulin and the maker of tirzepatide (Mounjaro for type-2 diabetes, Zepbound for obesity), produces an outsized base of pharma RSU, ISO, and IRC § 83(b) election cases. Elevance Health (the former Anthem, headquartered at 220 Virginia Avenue) anchors the national health-insurance industry with corresponding RSU and deferred-compensation issues. Cummins Inc., headquartered in Columbus but with substantial Indianapolis corporate presence, drives engine-manufacturing RSU and ESPP work. The Indianapolis Motor Speedway and the Indianapolis 500 generate motorsports 1099 issues for drivers, mechanics, and engineers. The NCAA national office, the Indianapolis Colts, the Indiana Pacers, the Indiana Fever, and Indy Eleven create athlete and admin payroll questions. The FedEx Express Air Hub at Indianapolis International (IND) — the second-largest FedEx air hub in the world — produces aircrew W-2 sourcing issues under 49 U.S.C. § 40116. Surrounding Marion County are corn and soybean farms with Schedule F losses, Stellantis (Chrysler) auto-manufacturing facilities in Tipton and Kokomo, and a sizable Asian-Indian and Mexican-American immigrant population that brings FinCEN Form 114 (FBAR) compliance into nearly every household-finance review.

Your tax rights as an Indianapolis 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 Indiana Adjusted Gross Income Tax Act (Ind. Code 6-3), the Tax Administration provisions of Ind. Code 6-8.1, the County Local Income Tax statute (Ind. Code 6-3.6), and the Indiana Taxpayer Bill of Rights at Ind. Code § 6-8.1-1-3. Knowing both is the difference between a clean resolution and a missed 60-day Indiana Tax Court petition deadline that turns into a state tax warrant filed with the Marion County Clerk against your real and personal 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. Indiana mirrors this through Form POA-1 Power of Attorney filed with the Indiana Department of Revenue, authorized under Ind. Code § 6-8.1-3-8.

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 Tax Court holds regular trial sessions in Indianapolis at the Birch Bayh Federal Building, 46 E Ohio Street.

Right to Indiana Tax Court review

Ind. Code § 6-8.1-9-1 gives you 60 days from a Letter of Findings to petition the Indiana Tax Court — a dedicated state tax court established at Ind. Code 33-26 with exclusive original jurisdiction over Indiana Department of Revenue final determinations. The Indiana Tax Court is seated at 115 W Washington Street, Room 1130, Indianapolis IN 46204. Indiana is one of only a handful of U.S. states (alongside New Jersey, Oregon, and Hawaii) with a dedicated tax court of exclusive original jurisdiction. Decisions are reviewable directly by the Indiana Supreme 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 in 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. Indiana runs a parallel Offer-in-Compromise authority under Ind. Code § 6-8.1-3-17(c), with hardship and insolvency standards similar to the federal program. Both regimes require all returns filed 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 Indianapolis 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 Indianapolis taxpayers, a federal OIC does not resolve Indiana state liability; we run a parallel Indiana OIC under Ind. Code § 6-8.1-3-17(c) where the state debt is real, recognizing that the Indiana DOR applies tighter financial-disclosure standards than the IRS.

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 — an under-used resolution path for Indianapolis taxpayers between $50,000 and $250,000 in federal debt. Indiana runs its own state Payment Plan program through INTIME, the Indiana Taxpayer Information Management Engine portal.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks an Indianapolis property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Marion County Recorder encumber title; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing on a Meridian-Kessler, Broad Ripple, Carmel, or Fishers transaction.

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. Indiana state tax warrants follow a parallel track under Ind. Code § 6-8.1-8-2, recorded by the county sheriff and enforced through the Marion County Clerk.

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) for Indian, Mexican, and Polish bank accounts, S-corporation reasonable-compensation, Eli Lilly RSU and ISO disposition timing, and IRC § 83(b) election validation. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Indianapolis trial sessions are held at the Birch Bayh Federal Building.

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. Indiana penalties under Ind. Code § 6-8.1-10-2.1 follow a separate reasonable-cause analysis.

Twelve types of Indianapolis tax matters we handle

Federal cases for Indianapolis residents and businesses, framed against the Indiana DOR overlay and the Marion County Local Income Tax where it matters.

Eli Lilly RSU and ISO disputes

Eli Lilly & Company is headquartered at 893 S Delaware Street in downtown Indianapolis, the dominant U.S. manufacturer of insulin and the maker of tirzepatide (Mounjaro and Zepbound). Pharma RSU vesting under IRC § 83 generates ordinary-income W-2 inclusion at vest with a forced supplemental-wage withholding of 22% (or 37% above $1 million in aggregate). ISO disqualifying-disposition events under IRC § 422, AMT bargain-element inclusion under IRC § 56, and IRC § 83(b) election timing on restricted-stock grants drive most of our pharma cases. The combined federal-plus-Indiana-plus-Marion-County effective rate on RSU income reaches 42.07% (37% federal + 3.05% state + 2.02% CLIT).

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Indianapolis restaurant, hospitality, construction, and trucking owners are the most frequent targets. The IRS uses Form 4180 interviews to identify responsible persons. Indiana pursues a parallel responsible-officer claim under Ind. Code § 6-2.5-9-3 for unpaid sales-tax trust funds and Ind. Code § 6-3-4-8 for withholding tax.

FedEx air-cargo crew sourcing

The FedEx Express Air Hub at Indianapolis International (IND) is the second-largest FedEx air hub in the world. Federal law (49 U.S.C. § 40116) limits state taxation of flight-crew wages to the state of residence and any state where the employee spends more than 50% of scheduled flight time. Audits frequently assert non-resident Indiana liability that the federal statute preempts. The Indiana DOR applies a parallel rule for ground-based hub workers, with Marion County CLIT layered on residents who work at the IND hub.

Indy 500 driver and crew 1099 work

The Indianapolis Motor Speedway hosts the Indianapolis 500, the Brickyard 400, and the Indianapolis Grand Prix — producing 1099 issues for drivers, race engineers, mechanics, and sponsorship-contract earners. IRC § 162 ordinary-and-necessary expense deductions, IRC § 199A qualified-business-income calculations for self-employed motorsports professionals, and multi-state sourcing of prize money make this a frequent niche engagement.

Notice of Federal Tax Lien

NFTLs filed with the Marion County Recorder (or the Hamilton, Hendricks, Johnson, Boone, or Hancock County recorders for suburban Indianapolis) encumber title and trigger CDP rights under IRC § 6320. A parallel Indiana state tax warrant may be filed by the DOR under Ind. Code § 6-8.1-8-2 with the Marion County Clerk and the Marion County Sheriff.

IRS bank or wage levy

Bank levies on accounts held at Old National Bank, First Merchants, Chase, Fifth Third, Huntington, or any Indiana-chartered institution. Wage levies hit Indianapolis employers within days of CP90 or LT11 issuance — we move on Form 12153 CDP requests and Form 433-F hardship submissions concurrently.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. Indianapolis International serves a large Asian-Indian population with regular travel to family in India; passport revocation hits this community 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. Indianapolis has a sizable Asian-Indian community concentrated in Carmel, Fishers, and West Lafayette, plus a Mexican-American population on the southwest side, plus pockets of African and Eastern European immigrants. Streamlined Filing Compliance Procedures are a frequent engagement for accounts at HDFC Bank, ICICI Bank, State Bank of India, Banamex, and BBVA Mexico.

NCAA, Colts, Pacers, Fever athlete and admin payroll

The NCAA national office is headquartered at 700 W Washington Street in Indianapolis. The Indianapolis Colts (NFL), Indiana Pacers and Indiana Fever (NBA / WNBA), Indy Eleven (USL Championship), and Indianapolis Indians (AAA baseball) all roster Indiana-resident athletes and traveling rosters. Athlete state-sourcing under the so-called “jock tax” allocates wage and bonus income to each state in which a game is played, requiring multi-state filing and IRC § 901 foreign-tax-credit-style analysis at the state level.

Innocent Spouse Relief

IRC § 6015 relief for spouses jointly liable on a return where the other spouse's items caused the deficiency. We file Form 8857 with a clean factual record — common in divorces involving Indianapolis pharma executives whose RSU income, ISO exercises, and 83(b) election decisions the other spouse never saw.

Schedule F agricultural losses

Marion County is urban Indianapolis, but the surrounding counties of Hamilton, Hendricks, Johnson, Boone, Shelby, and Hancock include substantial corn and soybean acreage. Schedule F losses, the IRC § 461(l) excess-business-loss limitation, IRC § 175 soil and water conservation expense, and the IRC § 1301 income-averaging election are routine engagements for farm clients in the Indianapolis MSA.

Unfiled returns and SFR substitutes

When the IRS files a Substitute for Return under IRC § 6020(b), the assessed tax is almost always overstated. Filing the correct original return is the first move — it routinely reduces the balance. Indiana runs a parallel substitute-return process under Ind. Code § 6-8.1-5-1, and the DOR uses federal return matching to issue a Proposed Assessment whenever a federal SFR posts.

Nine common causes of tax debt for Indianapolis taxpayers

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

1. Pharma RSU and ISO under-withholding

An Eli Lilly RSU vests; the company withholds 22% federal supplemental, which leaves a six-figure shortfall against the 37% top bracket for executives. Add 3.05% Indiana state and 2.02% Marion County CLIT, and a $500,000 vesting event arrives in April with $75,000 to $100,000 still owed. The CP14 lands in May, the Indiana DOR Proposed Assessment follows within 90 days.

2. Self-employment underpayment

Indianapolis 1099 physicians at IU Health, Eskenazi Health, Community Health Network, and Franciscan Health, consultants, and Schedule C operators file with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654 and parallel Indiana penalty under Ind. Code § 6-8.1-10-2.1.

3. Business closure

When an LLC or S-corp closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Indiana pursues a parallel responsible-officer claim under Ind. Code § 6-3-4-8 for income-tax withholding and Ind. Code § 6-2.5-9-3 for trust-fund sales tax.

4. Divorce and joint-return fallout

A jointly-filed return tied to a now-former spouse's understatement leaves both parties liable until Innocent Spouse relief under IRC § 6015 is granted. Marion County divorce filings track the federal record, and unresolved RSU or ISO income from a pharma-executive spouse is a recurring driver.

5. Identity theft and fraudulent returns

A return filed in your name with refund redirected. Form 14039 opens the IRS identity-theft case; the assessment must be corrected, not just protested.

6. Cryptocurrency CP2000 surprise

Exchanges issue Form 1099-DA (introduced 2025), and the IRS computer matches reported gains. Missed basis records turn into ordinary-income assessments at the full sale price. Indianapolis has a meaningful retail crypto population, particularly in the tech corridor around Salesforce Tower (211 N Pennsylvania Street) and the Hamilton County tech employers.

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. Indiana imposes a parallel 10% one-time late-filing penalty under Ind. Code § 6-8.1-10-2.1 plus 10% on the late-payment side.

8. Real-estate sale without estimated tax

A Meridian-Kessler, Broad Ripple, downtown condo, or Carmel property sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Investor flips taxed at ordinary-income rates — not capital-gain — under the dealer-status rules of IRC § 1221.

9. Indiana Use Tax on out-of-state purchases

Ind. Code § 6-2.5-3-2 imposes a 7% Use Tax on goods purchased out of state (online retailers, vehicles bought across state lines, RVs and boats brought into Indiana) and used in the state. The DOR enforces aggressively through vehicle-registration cross-matching and out-of-state retailer reporting; many Indianapolis taxpayers discover the liability years late.

Eight tax liabilities that pull in Indianapolis taxpayers

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

Failure to file federal return

IRC § 6651(a)(1) imposes 5%/month, max 25%, plus interest under IRC § 6601. The Indiana mirror is Ind. Code § 6-8.1-10-2.1, a 10% one-time penalty on the unpaid state liability, with separate 10% late-payment exposure on the same balance.

Failure to file Indiana state return

Ind. Code § 6-8.1-10-2.1 imposes a late-filing penalty separate from the federal penalty. The Indiana DOR may issue a Proposed Assessment under Ind. Code § 6-8.1-5-1, triggering a 60-day protest window and, if the protest fails, a Letter of Findings opening the 60-day Indiana Tax Court petition deadline under Ind. Code § 6-8.1-9-1.

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.

Indiana Sales Tax delinquency

Ind. Code § 6-2.5-2-2 imposes a 7% state sales tax with no local sales-tax add-on (uniform statewide). Personal liability for responsible persons under Ind. Code § 6-2.5-9-3 pierces the corporate veil for trust-fund sales tax. The Indiana DOR uses the Registered Retail Merchant Certificate revocation as an enforcement lever — pulling a restaurant's certificate effectively closes the business.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Indiana applies a similar responsible-person rule to withheld state income tax under Ind. Code § 6-3-4-8.

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.

Indiana Use Tax assessment

Ind. Code § 6-2.5-3-2 imposes a 7% Use Tax on out-of-state purchases brought into Indiana. The DOR pursues unreported Use Tax through vehicle-registration cross-matching and out-of-state retailer reporting. Voluntary disclosure agreements under Ind. Code § 6-8.1-3-17 can resolve historical exposure on favorable terms with the Indiana DOR Special Investigations Section.

Marion County Local Income Tax

Ind. Code § 6-3.6 authorizes a County Local Income Tax administered by the Indiana DOR alongside the state return. The Marion County rate is 2.02%, allocated by the Marion County Local Income Tax Council to public-safety, certified-shares, and economic-development purposes. CLIT assessments piggyback on federal and state income tax adjustments — a CP2000 federal adjustment routinely triggers a Marion County CLIT follow-on assessment within months.

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 Marion County Recorder.

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	$148,742	IRC § 6159 Installment Agreement	Accepted at $25/month, partial-pay
2024	$132,118	Streamlined Installment Agreement	Accepted at $25/month
2023	$127,495	Partial-Pay Installment Agreement	Accepted at $50/month
2023	$121,860	IRC § 6159 Installment Agreement	Accepted at $25/month
2022	$114,233	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 Indiana Department of Revenue.

Why Victory Tax Lawyers for an Indianapolis federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Indiana-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 Indianapolis at the Birch Bayh Federal Building, 46 E Ohio Street. IRS administrative practice runs on Form 2848 Power of Attorney, which is accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Indianapolis clients never need a separately admitted Indiana attorney because the case is, at its core, federal.

For administrative work before the Indiana Department of Revenue — protests, audit responses, OIC submissions, Letter of Findings replies, and Payment Plan requests — we file Form POA-1 Power of Attorney and handle the matter remotely. When a case must move to the Indiana Tax Court (the dedicated Tier-2 court at 115 W Washington Street, Room 1130, established under Ind. Code 33-26 with exclusive original jurisdiction over Indiana DOR final determinations) or an Indiana state court, we coordinate with locally admitted Indiana counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure for pharma RSU and ISO holders, 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 an Indiana-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Indianapolis 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 drive to Robertson Boulevard.

Our seven-step process for Indianapolis clients

Free consultation

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

Engagement letter

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

Form 2848 and POA-1

We file the federal Power of Attorney with the IRS and Form POA-1 with the Indiana DOR, register on the CAF system, and step in as the contact of record.

Transcript and CSED analysis

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

Strategy memo

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

Filing and negotiation

We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, or an Indiana Tax Court petition through local counsel — and handle every IRS and Indiana DOR contact.

Compliance monitoring

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

Two collection clocks: federal CSED and Indiana's tax-warrant rule

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.

Indiana runs a parallel state collection rule. Under Ind. Code § 6-8.1-5-2, the Indiana DOR must issue a Proposed Assessment within three years of the return's due date (six years for omissions exceeding 25% of gross income, no limit for fraud or unfiled returns). Once an Indiana tax warrant is filed under Ind. Code § 6-8.1-8-2 with the Marion County Clerk, the warrant operates as a judgment against the taxpayer's real and personal property and remains enforceable for 10 years, renewable for additional 10-year periods. Many Indianapolis taxpayers carry a federal CSED that will expire at or near the same time as the state warrant, but the state warrant can be re-filed indefinitely. Pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.

Indianapolis tax authorities and venues

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

Internal Revenue Service — Indianapolis TAC

The federal tax authority, at irs.gov. The Indianapolis Taxpayer Assistance Center operates at 575 N Pennsylvania Street, Room 200, Indianapolis IN 46204, inside the Birch Bayh Federal Building. Appointments required.

U.S. Tax Court — Indianapolis trial sessions

The U.S. Tax Court holds regular trial sessions in Indianapolis at the Birch Bayh Federal Building, 46 E Ohio Street. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

Indiana Department of Revenue

The state tax authority, at in.gov/dor. Indianapolis headquarters at 100 N Senate Avenue, Room N105, Indianapolis IN 46204. Administers the 3.05% flat personal income tax (phasing to 2.95% by 2026), the 4.9% corporate income tax, the 7% state sales tax under Ind. Code § 6-2.5-2-2, withholding tax, Use Tax under Ind. Code § 6-2.5-3-2, and County Local Income Tax under Ind. Code § 6-3.6 (administered on behalf of all 92 Indiana counties).

Indiana Tax Court

A dedicated state tax court of exclusive original jurisdiction, authorized under Ind. Code 33-26 and seated at 115 W Washington Street, Room 1130, Indianapolis IN 46204. Hears appeals of Indiana DOR final determinations and Indiana Board of Tax Review property-tax decisions. 60-day petition deadline from the Letter of Findings under Ind. Code § 6-8.1-9-1. Indiana is one of only a handful of U.S. states with a dedicated tax court of exclusive original jurisdiction; decisions are reviewable directly by the Indiana Supreme Court.

Marion County Treasurer

The county tax-collection authority for Indianapolis (operating under the consolidated Indianapolis-Marion County Unigov structure). Office at 200 E Washington Street, Suite E1122, Indianapolis IN 46204. Page: indy.gov/agency/marion-county-treasurer. Administers Marion County property-tax billing and collection.

Marion County Assessor

The county assessment authority. Office at 200 E Washington Street, Suite 1360, Indianapolis IN 46204. Sets the assessed value of Indianapolis property — the starting point for the county tax bill, subject to Indiana's constitutional Circuit Breaker caps at 1% of assessed value for residential homesteads, 2% for agricultural land and other residential, and 3% for non-residential under Ind. Const. Art. 10 § 1.

City of Indianapolis Department of Finance

The municipal finance authority at 200 E Washington Street, Suite 2222, Indianapolis IN 46204. Indianapolis does not impose a separate municipal income tax (Marion County collects 2.02% CLIT under Ind. Code § 6-3.6 instead). Local revenue includes the Marion County food-and-beverage tax, the Capital Improvement Board admissions and supplemental auto-rental taxes, and the Marion County innkeeper's tax.

U.S. District Court — Southern District of Indiana, Indianapolis

Refund suits filed after payment of tax and exhaustion of administrative remedies under IRC § 7422 may be brought in the U.S. District Court (S.D. Ind., Indianapolis Division, Birch Bayh Federal Building, 46 E Ohio Street, Indianapolis IN 46204) 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. Indianapolis cases run through the Appeals offices serving the Midwest region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Taxpayer Advocate Service — Indianapolis

An independent organization within the IRS that helps when normal channels stall. The Indianapolis TAS office serves taxpayers across central and southern Indiana. Page: taxpayeradvocate.irs.gov.

Speak with a tax attorney about your Indianapolis matter

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

Call (800) 883-8301 Free Consultation

Frequently asked questions — Indianapolis tax

Does Indiana have a state income tax?

Yes. Indiana has a 3.05% flat personal income tax under Ind. Code § 6-3-2-1, phasing down to 2.95% by 2026 under HEA 1002 and SB 451. On top of that flat state rate, Marion County imposes a 2.02% County Local Income Tax under Ind. Code § 6-3.6 — administered by the Indiana DOR but specific to county of residence. The effective state-and-local personal rate for an Indianapolis resident is 5.07%. Corporate income tax is 4.9% under Ind. Code § 6-3-2-1.5. State sales tax is 7% under Ind. Code § 6-2.5-2-2, uniform statewide with no local sales-tax add-on. Indiana repealed its inheritance tax effective January 1, 2013; estate tax exposure for Indiana residents is federal-only.

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

The U.S. Tax Court holds regular trial sessions in Indianapolis itself at the Birch Bayh Federal Building, 46 E Ohio Street. A taxpayer anywhere in central or southern Indiana can request the Indianapolis 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 Indiana Tax Court and how does it work?

The Indiana Tax Court is a dedicated state tax court of exclusive original jurisdiction, established by the Indiana General Assembly and codified at Ind. Code 33-26. It is seated at 115 W Washington Street, Room 1130, Indianapolis IN 46204. Indiana is one of only a handful of U.S. states (alongside New Jersey, Oregon, and Hawaii) with a dedicated tax court of exclusive original jurisdiction over state tax disputes. The court hears appeals of Indiana DOR final determinations (Letters of Findings) and Indiana Board of Tax Review property-tax decisions. The petition deadline is 60 days from the Letter of Findings under Ind. Code § 6-8.1-9-1 — tighter than the federal 90-day Tax Court deadline. Decisions are reviewable directly by the Indiana Supreme Court. Victory Tax Lawyers refers Indiana Tax Court litigation to locally admitted Indiana counsel; we handle the federal portion and Indiana DOR administrative work directly under Form POA-1.

What is Indiana's collection statute of limitations?

Ind. Code § 6-8.1-5-2 gives the Indiana DOR three years from a return's due date to issue a Proposed Assessment (six years for omissions exceeding 25% of gross income, no limit for fraud or unfiled returns). Once an Indiana tax warrant is filed under Ind. Code § 6-8.1-8-2 with the Marion County Clerk, the warrant operates as a judgment against the taxpayer's real and personal property and remains enforceable for 10 years, renewable for additional 10-year periods. The federal CSED under IRC § 6502 is also 10 years, but is not renewable — meaning an Indiana state warrant can outlive the federal collection clock if the DOR re-files. Pulling both records is the first step before agreeing to any payment plan that might restart a clock.

I work at Eli Lilly — what tax issues should I worry about with my RSU and ISO grants?

Three things sit on top of every Eli Lilly employee file we open. First, restricted stock units (RSUs) generate W-2 ordinary income at vest under IRC § 83(a); the company withholds 22% federal supplemental on the vesting value (or 37% above $1 million in aggregate supplemental wages), which is almost always under-withholding for executives in the 32% to 37% brackets. Second, incentive stock options (ISOs) under IRC § 422 create alternative-minimum-tax bargain-element exposure under IRC § 56 at exercise, then capital-gain or ordinary-income treatment at sale depending on whether the holding period satisfies the two-year-from-grant and one-year-from-exercise rules. A disqualifying disposition converts the bargain element to W-2 ordinary income. Third, IRC § 83(b) elections on restricted-stock grants (filed within 30 days of grant) accelerate ordinary-income recognition to the grant date at the then-current fair market value — powerful for early-stage pharma stock, costly if the value drops or the employee leaves. The combined federal-plus-Indiana-plus-Marion-County effective rate on RSU income reaches 42.07%.

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

Yes. The IRS and the Indiana Department of Revenue operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to Indiana under the state's federal-change reporting rule (Ind. Code § 6-3-4-6), and vice versa. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the Indiana return. Because Indiana maintains a 3.05% flat rate plus the 2.02% Marion County CLIT, a federal adjustment now produces a predictable state and county follow-on calculation.

Does Indiana offer an Offer in Compromise equivalent to the federal program?

Yes. The Indiana DOR accepts Offers in Compromise under Ind. Code § 6-8.1-3-17(c), applying a doubt-as-to-collectibility framework analogous to the federal program. Hardship and insolvency standards are similar to the IRS Form 656 analysis, but the Indiana DOR typically requires tighter documentation and a more conservative Reasonable Collection Potential calculation. All Indiana returns must be filed before consideration, and a financial-disclosure package is required. We typically run an Indiana OIC in parallel with the federal Offer where both debts are real. Indiana also operates a separate Voluntary Disclosure Agreement program through the Special Investigations Section for taxpayers with unreported historical exposure who come forward proactively.

I work for FedEx at the IND air hub but live in another state — am I taxed by Indiana?

Federal law — 49 U.S.C. § 40116(f) — preempts state taxation of flight-crew wages except in the crew member's state of residence and any state where the crew member performs more than 50% of scheduled flight time. The FedEx Express Air Hub at Indianapolis International is the second-largest FedEx air hub in the world, but a pilot or flight engineer domiciled in Florida, Texas, Tennessee, or another non-resident state cannot be taxed by Indiana on wages earned outside Indiana airspace. The same federal preemption does not extend to ground-based hub workers (mechanics, sorters, ramp agents), who are taxed by Indiana on Indiana-sourced wages and by Marion County on the 2.02% CLIT if Marion County is their county of residence on the first business day of the year.

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

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 Indianapolis. For Indiana DOR administrative work, we file Form POA-1 Power of Attorney and handle the matter remotely. For formal litigation in the Indiana Tax Court or an Indiana state court, we co-counsel with locally admitted Indiana attorneys. Most engagements — audit defense, OIC, IA, levy release, Tax Court — are federal and stay entirely with our firm.

I have an Indian, Mexican, or Polish bank account — do I have to report it?

Yes, if the aggregate value of all foreign financial accounts you own or have signature authority over exceeded $10,000 at any point during the calendar year. FinCEN Form 114 (FBAR) is due April 15 with an automatic extension to October 15. Non-willful failure to file carries up to a $10,000 civil penalty per violation; willful failure can reach the greater of $100,000 or 50% of account balances. The IRS Streamlined Filing Compliance Procedures — both Domestic and Foreign — offer a path to bring accounts at HDFC Bank, ICICI Bank, State Bank of India, Banamex, BBVA Mexico, PKO Bank Polski, and similar institutions into compliance with substantially reduced penalty exposure. Indianapolis's Asian-Indian community, concentrated in Carmel, Fishers, and West Lafayette, makes this a frequent engagement.

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). Indiana follows a parallel filing-compliance posture; the DOR may issue a Proposed Assessment under Ind. Code § 6-8.1-5-1 when a taxpayer fails to file, and Marion County CLIT obligations accrue alongside the state return whether filed or not.

Can the IRS or the Indiana DOR levy my Indianapolis 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 Old National Bank, First Merchants, Chase, Fifth Third, Huntington, or any Indiana-chartered institution and serve wage levies on Indianapolis employers. 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). The Indiana DOR issues state tax warrants under Ind. Code § 6-8.1-8-2, which are filed with the Marion County Clerk and operate as judgments enforceable through the county sheriff — including bank account levies, wage garnishments, and personal-property seizures.

What is the Marion County Local Income Tax and how does it work?

The Marion County Local Income Tax (CLIT) is a county-level income tax authorized under Ind. Code § 6-3.6 and administered by the Indiana Department of Revenue on behalf of all 92 Indiana counties. Marion County's combined rate is 2.02%, set by the Marion County Local Income Tax Council and allocated to public-safety, certified-shares, and economic-development purposes. CLIT applies to residents of the county on January 1 of the tax year — a Carmel resident (Hamilton County) working in downtown Indianapolis pays Hamilton County CLIT at the Hamilton County rate, not Marion County CLIT, even though their employer is Marion-County-based. CLIT assessments piggyback on federal and state income tax adjustments, and the Indiana DOR enforces unpaid CLIT through the same tax-warrant procedure that applies to state income tax under Ind. Code § 6-8.1-8-2.

I am a Colts, Pacers, or Fever player — what tax issues should I expect?

Professional athletes resident in Indianapolis pay federal income tax (up to 37%), Indiana income tax (3.05% flat, phasing to 2.95%), Marion County CLIT (2.02%), and self-employment-style FICA depending on whether the contract treats them as W-2 employees or independent contractors. Multi-state “jock tax” allocation requires filing returns in every state where games are played, with day-counts driving wage sourcing. The IRS audits athlete returns for endorsement-income sourcing, training-camp residency claims, and entity-structure questions around image-rights LLCs. Indiana applies a parallel duty-day analysis under Ind. Code § 6-3-2-2.5 for non-resident athletes playing in Indianapolis — visiting team payrolls owe Indiana income tax and Marion County CLIT on Indiana-sourced game-day income.

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. An Indiana OIC under Ind. Code § 6-8.1-3-17(c) typically runs four to nine months on a parallel track.

Will hiring a tax attorney stop IRS collection action immediately?

Once Form 2848 is on file, the IRS routes all communication through the attorney and stops contacting the taxpayer directly. Active levies are not automatically lifted by the POA filing alone — release requires either a financial showing under IRC § 6343, a CDP filing under IRC § 6330, or an installment-agreement / OIC submission that triggers the IRC § 6331(k) collection bar. We move on those concurrently when a levy is in place. Indiana state collection follows a similar pattern: a Form POA-1 routes state contact, and a pending Indiana OIC or Payment Plan request pauses enforcement under Ind. Code § 6-8.1-8-2.

About the author

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

Page last reviewed: May 25, 2026. Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Indiana statute citation references the Indiana Code maintained by the Indiana General Assembly. 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 Indiana Department of Revenue, the U.S. Tax Court, the Indiana Tax 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 State of Indiana; where an Indiana state-court appearance or Indiana Tax Court 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. § 83 — Property Transferred in Connection with Performance of Services (RSU vesting)
26 U.S.C. § 422 — Incentive Stock Options
26 U.S.C. § 56 — Alternative Minimum Tax adjustments (ISO bargain element)
49 U.S.C. § 40116 — State taxation of air-carrier wages
Ind. Code § 6-3-2-1 — Indiana flat-rate personal income tax (3.05% phasing to 2.95%)
Ind. Code § 6-3-2-1.5 — Indiana corporate income tax (4.9%)
Ind. Code § 6-3-2-2.5 — Indiana non-resident athlete duty-day allocation
Ind. Code § 6-3-4-6 — Indiana federal-change reporting
Ind. Code § 6-3-4-8 — Indiana withholding-tax responsible-officer liability
Ind. Code § 6-3.6 — County Local Income Tax (Marion County 2.02%)
Ind. Code § 6-2.5-2-2 — Indiana state sales tax (7%)
Ind. Code § 6-2.5-3-2 — Indiana Use Tax
Ind. Code § 6-2.5-9-3 — Indiana sales-tax responsible-person liability
Ind. Code § 6-8.1-3-8 — Indiana DOR Power of Attorney authority
Ind. Code § 6-8.1-3-17 — Indiana Voluntary Disclosure and Offer in Compromise authority
Ind. Code § 6-8.1-5-1 — Indiana Proposed Assessment procedure
Ind. Code § 6-8.1-5-2 — Indiana assessment statute of limitations
Ind. Code § 6-8.1-8-2 — Indiana tax warrant procedure
Ind. Code § 6-8.1-9-1 — Indiana Tax Court petition window (60 days)
Ind. Code § 6-8.1-10-2.1 — Indiana late-filing and late-payment penalty
Ind. Code 33-26 — Indiana Tax Court enabling statute
Ind. Const. Art. 10 § 1 — Property-tax “Circuit Breaker” constitutional caps (1% / 2% / 3%)