Tax Attorney in Little Rock, AR

The Arkansas Tax Appeals Commission is a structurally independent state-tax tribunal created by the Arkansas General Assembly in 2023 under Ark. Code §26-18-1101. Before the Commission stood up, contested DFA assessments traveled through the Office of Hearings and Appeals, an administrative tribunal sitting inside the executive branch at 1816 W 7th Street, Room 1380. The Commission's independence is its central design feature: members are appointed for fixed terms, and the body does not report up the same chain as the auditors who issued the assessment. The petition window is 90 days from DFA's final assessment under Ark. Code §26-18-1105, materially longer than the 30-day windows in many other states. Because the Commission is new, the body of procedural precedent is still developing, and early petitioners are effectively shaping the rules of the road.

UAMS academic-faculty W-2 income flows through normal employer withholding. Baptist Health, CHI St. Vincent, and Arkansas Children's moonlighting and locum coverage typically come as 1099-NEC and require quarterly estimated payments under IRC §6654 to avoid an underpayment penalty. The 1099 income generates self-employment tax under IRC §1401 (15.3% on the first $168,600 of net SE earnings for 2024, with adjustments thereafter), and Schedule C lets you deduct ordinary and necessary business expenses tied to the moonlighting practice — CME, malpractice tail, professional licensure, and home-office expenses where they qualify under IRC §280A. For physicians who incorporate as a PA or PLLC to handle the 1099 work, the choice between disregarded-entity treatment and S-corp election under IRC §1362 turns on the reasonable-compensation analysis and the SE-tax savings from distributions.

Under IRC §112, compensation earned during any month in which you served in a designated combat zone is excluded from gross income (enlisted personnel and warrant officers in full; commissioned officers up to a monthly cap tied to the highest enlisted pay plus imminent-danger pay). Coverage typically begins the date you enter the combat zone and ends 180 days after you leave or after recovery from injury. IRC §7508 separately extends filing, payment, and collection deadlines for the entire deployment plus 180 days. MSRRA preserves your spouse's state-of-legal-residence election regardless of physical move to Arkansas. LRAFB C-130 and C-17 crews rotating into CENTCOM theaters generate combat-zone exclusion claims that the W-2 sometimes misses; verify the W-2 Box 12 Q code matches your actual combat-zone months. Corrections sometimes require coordination through DFAS rather than direct W-2c from LRAFB finance.

The U.S. Tax Court holds Little Rock trial sessions at the Richard Sheppard Arnold U.S. Courthouse, 500 W Capitol Avenue, Little Rock AR 72201. A petitioner designates Little Rock as the preferred place of trial on the petition under Tax Court Rule 140. Sessions are scheduled on rotation rather than monthly. Small-tax-case procedure under IRC §7463 is available for deficiencies of $50,000 or less per year per period and uses simplified evidentiary rules. The same courthouse hosts the U.S. District Court for the Eastern District of Arkansas, Little Rock Division, where federal refund actions under IRC §7422 are heard.

Delta farm income flows through Schedule F (Form 1040) for sole proprietors and through Form 4835 for landowners who share-crop without material participation. Several federal-tax provisions matter: IRC §175 allows current expensing for soil and water conservation expenditures up to 25% of gross farm income, IRC §1301 income averaging spreads a high-yield year across the prior three years (significantly valuable in a volatile commodities cycle), IRC §1014 step-up applies on inherited farmland (one of the most important basis levers for multi-generational family operations), and IRC §2032A special-use valuation lets qualifying heirs value farmland at its agricultural use rather than fair market value for estate-tax purposes (up to a cap, currently around $1.39 million for 2025). Persistent Schedule F losses draw IRC §183 hobby-loss audit attention; documenting the profit motive with crop-yield records, marketing-plan files, and lender financial statements helps significantly. Tyson contract-grow chicken-house income is generally Schedule F or Schedule C depending on the operator's role.

Under Ark. Code §26-18-306, DFA generally has three years from the due date of the return to assess additional Arkansas tax. The period extends to six years for substantial omissions, and is unlimited for unfiled returns and for fraud. After DFA issues a final assessment, the taxpayer has 90 days under Ark. Code §26-18-1105 to file a petition with the Arkansas Tax Appeals Commission — miss that window and the assessment becomes final on the state administrative side, leaving only a pay-then-sue refund action in Pulaski County Circuit Court. The federal IRS Collection Statute Expiration Date (10 years from assessment under IRC §6502) runs independently from the state SOL. Plan around both clocks before responding to either one.

Yes. A levy under IRC §6331 reaches property and rights to property held by or for the taxpayer, including checking, savings, and brokerage accounts. Once Arvest, Bank OZK, Centennial Bank, Simmons Bank, or any other Arkansas-headquartered institution receives a levy, the bank segregates the account and holds funds for 21 days under IRC §6332(c) before remittance. Acting in the 21-day window matters: a properly-filed CDP request, an accepted CNC, an accepted IA, or an accepted OIC suspends the levy before the bank remits. For active-duty filers, the Servicemembers Civil Relief Act provides additional layered protections that sometimes pause levy execution independently of IRS collection process.

Probably yes for the federal trust-fund portion. IRC §6672 assesses a Trust Fund Recovery Penalty against any "responsible person" who "willfully" failed to pay over withheld taxes — the FICA and federal income-tax withholding portion of Form 941. The IRS conducts a Form 4180 interview to identify responsible persons. Anyone with check-signing authority, payroll-decision authority, or knowledge of the unpaid taxes can be assessed personally — that means founders, head-of-finance, and sometimes a controller. For Little Rock fintech, agtech, and healthcare-services startups, this often catches multiple people because cap-table authority and check-signing authority overlap. On the state side, DFA pursues withholding and sales-tax responsible-party assessments under Ark. Code Title 26 in parallel.

Yes. IRC §7345 authorizes the IRS to certify "seriously delinquent" tax debt — currently $62,000 for 2026, indexed for inflation — to the State Department, which may then deny passport renewal or revoke an active passport. The certification reverses when the debt is paid, an IA is in place, an accepted OIC is in force, an active CDP hearing is pending, or Innocent Spouse Relief is in process. UAMS faculty with international research collaborations, Arkansas Children's specialists handling overseas pediatric referrals, state employees on capitol-side foreign-trade missions, and Vietnamese-American and Marshallese filers with travel obligations to family abroad all face real exposure. Decertification typically processes within 30 days once a qualifying resolution is in place. Active-duty military filers have a separate exception under §7345(b)(2)(B) for combat-zone status.

Arkansas does not impose a state estate tax or a state inheritance tax. The federal estate tax under IRC §2001 applies above the basic exclusion amount ($13.99 million per individual for 2025, indexed annually), and IRC §2032A special-use valuation lets qualifying heirs value Delta farmland at its agricultural use rather than fair market value (subject to a cap currently around $1.39 million for 2025 and a 10-year recapture period if the heir disposes of the land or stops the qualified use). IRC §1014 basis step-up applies regardless of whether the estate owes federal tax; this is the dominant planning lever for multi-generational rice, cotton, and soybean operations. Since Arkansas does not impose a separate state estate tax, the analysis for Pulaski County decedents is materially simpler than for residents of states like New York, Massachusetts, or Oregon.

Likely yes if you are a U.S. person under 31 USC §5314 and the aggregate maximum balance of all foreign financial accounts exceeds $10,000 at any point during the calendar year. FBAR (FinCEN Form 114) covers Vietnam-side Vietcombank, BIDV, Techcombank, and Sacombank accounts, signature authority on family-owned business accounts, and any brokerage holdings. Form 8938 under IRC §6038D applies at higher thresholds (typically $50,000 for an unmarried U.S. resident, $100,000 for married filing jointly). The Streamlined Filing Compliance Procedures address prior-year non-willful gaps and reduce penalty exposure substantially — this pathway has been particularly important for Vietnamese-American families whose pre-immigration banking relationships continued after resettlement at Fort Chaffee and across the Little Rock and northwest-Arkansas communities. Willful failure carries materially higher penalty exposure and possible criminal referral under 31 USC §5322.

Arkansas's combined sales-tax rate inside the city of Little Rock is 9% — 6.5% state, 1% Pulaski County, and 1.5% city — one of the highest combined rates in the United States. Marketplace facilitators (Etsy, Amazon, eBay, Walmart Marketplace) generally collect and remit Arkansas sales tax on your behalf for in-state buyers, but direct Shopify, Squarespace, and BigCommerce sales remain the seller's obligation. The South Dakota v. Wayfair, Inc., 138 S.Ct. 2080 (2018) economic-nexus framework applies to remote sellers shipping into Arkansas above the state's $100,000 or 200-transaction threshold. Mishandling the seller's-tax obligation produces DFA Notice of Assessment exposure for multiple years plus interest and penalty. Federal Schedule C deductibility of state sales tax collected-but-not-remitted is a separate trust-fund-style risk.

Federal tax-resolution fees vary by matter complexity. A straightforward Installment Agreement typically falls between $1,500 and $3,500. A full Offer in Compromise with Form 433 financial analysis runs $4,000 to $7,500. Audit defense depends on the audit type and the number of issues. A U.S. Tax Court petition with case workup and trial preparation generally starts at $6,000 and rises with case complexity. A combined federal-plus-DFA matter for a Little Rock small-business owner runs higher because it involves two agencies and two statutes. VTL provides a written fee quote after the free consultation. Cal Bar Rule 7.1 prohibits comparisons claiming we are cheaper or faster than competitors without verifiable substantiation, so we do not market on price.

Yes. Communications between you and a licensed attorney for the purpose of seeking legal advice are protected by federal common-law attorney-client privilege, subject to the usual exceptions (crime-fraud, waiver, third-party presence). The narrower federally-authorized tax practitioner privilege under IRC §7525 applies to non-attorney CPAs and EAs but does not extend to criminal-tax matters or to written tax-shelter communications. An attorney handling your tax case retains the broader privilege that survives criminal investigation, which matters significantly if a civil audit shifts to a Criminal Investigation Division referral — a pattern that appears in farm-loss substantiation disputes, high-volume crypto cases, and physician-compensation arrangements that overlap with anti-kickback or Stark concerns.

For administrative correspondence with DFA and the written petition filed with the Arkansas Tax Appeals Commission within 90 days of a final assessment, taxpayers may be represented by an attorney, CPA, or enrolled agent under Arkansas Form AR-2848 Power of Attorney. The Commission permits non-attorney representation in many administrative matters. For judicial review in Pulaski County Circuit Court (a pay-then-sue refund action), the Arkansas Court of Appeals, or the Arkansas Supreme Court, an attorney admitted in Arkansas is required. VTL handles the federal side of overlapping matters and the administrative DFA-and-Tax-Appeals-Commission side under AR-2848 PoA, then coordinates with Arkansas counsel where state-court litigation is necessary. Many DFA disputes resolve at the protest or Commission stage without reaching state court.