Tax Attorney in Maryland

Yes. Maryland imposes a graduated personal income tax administered by the Maryland Comptroller of the Treasury. The state rate runs through a series of brackets topping out at the highest statutory rate set under Md. Code Tax-General Title 10. On top of the state tax, every Maryland county and Baltimore City imposes a local "piggyback" income tax that historically ranges from roughly 2.25% to 3.20% depending on the jurisdiction. The combined state-plus-local rate puts Maryland in the top quartile of state effective income-tax burdens. Federal income tax (filed on Form 1040 with the IRS) applies separately and in full.

The U.S. Tax Court designates Baltimore as Maryland's place of trial. The Baltimore listing is small-tax-case sessions only, and the Court uses rented facilities rather than a permanent courtroom — the address appears on the notice of trial when a session is calendared. Petitioners who live closer to the DC suburbs (Bethesda, Rockville, Silver Spring, College Park, Bowie) sometimes designate Washington, D.C. as the preferred place of trial because that location holds regular-docket sessions in a permanent courtroom. The choice is made on the petition under Tax Court Rule 140 and can be amended by motion.

Under Md. Code Tax-General §13-1101, the Comptroller generally has three years from the date a return is filed or its due date (whichever is later) to assess additional tax. The period extends to six years for a substantial omission of income, and there is no statute-of-limitations bar at all where the taxpayer fails to file a return or files a fraudulent return. The federal IRS Collection Statute Expiration Date (10 years from assessment under IRC §6502) runs independently from the Maryland limitation.

Yes, and the two often run in parallel because Maryland conforms its starting point to federal adjusted gross income. The IRS examines federal income tax, federal employment tax, and federal excise tax. The Comptroller examines Maryland income tax, county piggyback tax, sales-and-use tax, and several smaller state-administered taxes. An IRS audit that produces a federal AGI change typically triggers a Comptroller follow-up adjustment under the Revenue Agent Report exchange program. Reporting a federal change to Maryland within the deadline under Md. Code Tax-General §13-409 is the taxpayer's affirmative obligation.

Yes. The Maryland Comptroller operates an Offer in Compromise program for state tax debts, accepting offers based on doubt as to liability or doubt as to collectibility. The taxpayer files Form MD-656 with supporting financial disclosure on Form MD-433-A or MD-433-B. The federal IRS OIC under IRC §7122 runs separately. Where a taxpayer has both federal and Maryland balances, we usually pursue the federal offer first — an accepted federal OIC and the financial disclosure that supports it often provides a strong record for the parallel Maryland offer.

Your CSED is calculated from the date of assessment, which appears on your IRS Account Transcript as Transaction Code 150 (return filed) or Transaction Code 290 (additional assessment). Add ten years, then add the days for any tolling events: pending OICs, CDP hearings, bankruptcy stays, and so on. The IRS publishes the CSED date internally on its CC ACTRA transcript; we pull this for clients as part of every engagement. The practical impact is significant — a debt assessed in 2016 may be approaching expiration in 2026, and aggressive enforcement near the CSED is common.

Yes. The IRS can issue a Form 668-W wage levy directed at any employer, including the U.S. government. Federal-employee wage levies are processed through the agency's payroll office and the Treasury Offset Program, and they reduce take-home pay according to Publication 1494 exempt-amount tables. Federal-employee filers also face a separate enforcement track under the Federal Employee/Retiree Delinquency Initiative (FERDI), which prioritizes IRS collection against federal-government workers and retirees. Securing a CNC determination, an accepted IA, or an accepted OIC stops the levy — we have moved Maryland-based federal employees out of FERDI flag status in similar matters.

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, not the employer's share. 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. On the state side, Maryland imposes a parallel personal-liability theory on responsible officers for unpaid state withholding and for unpaid sales-and-use tax under Md. Code Tax-General §11-601 and related provisions.

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. For Maryland federal employees with overseas postings, NIH researchers presenting at international conferences, and cleared contractors with foreign duty stations, decertification is often urgent and can be processed in 30 days or less.

Maryland is one of the few states that imposes both a state inheritance tax (on beneficiaries) and a separate state estate tax (on the estate itself). Inheritance tax under Md. Code Tax-General §7-204 is generally 10% of the value of property passing to collateral relatives — siblings, nieces, nephews, cousins, and unrelated beneficiaries. Lineal descendants (children, grandchildren), spouses, parents, grandparents, and direct ancestors are exempt. The tax is collected by the Register of Wills in the county where the estate is probated. Maryland's estate tax is a separate computation on the estate's total value and runs in addition to federal Form 706 where the federal exemption threshold is exceeded.

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 complexity. 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, etc.). 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. An attorney handling your tax case retains the broader privilege that survives criminal investigation.

A Tax Court trial is a bench trial — no jury — before a Judge or Special Trial Judge of the U.S. Tax Court. Baltimore is a small-tax-case place of trial only, meaning sessions there are limited to S-case dockets under IRC §7463 (deficiencies of $50,000 or less per year). The session opens with calendar call where the Court hears scheduling issues. Most cases on the calendar settle before trial; the IRS Office of Chief Counsel attorney for the case meets with petitioner's counsel during the days before trial. If trial proceeds, the petitioner bears the burden of proof on most issues, presents evidence and witness testimony, and the Court issues a written opinion typically within several months of trial.

Yes, generally. IRC §6331(k)(1) suspends levy action while an offer is pending and for 30 days after a rejection, and during any timely-filed Appeals review of a rejection. The IRS will not levy on you while a processable OIC is being evaluated. However, the IRS may still file a Notice of Federal Tax Lien during the OIC pendency to protect its position. CSED is also tolled during the pendency. A poorly-prepared OIC that gets returned (not rejected) does not provide the same protection — processability matters.

For an informal hearing within the Comptroller's Compliance Division and for an appeal to the Maryland Tax Court (an administrative tribunal), taxpayers may represent themselves or be represented by an attorney, a CPA, or another authorized representative under the Tax Court's rules. For judicial review proceeding in a Maryland circuit court, an attorney admitted in Maryland is required. VTL handles the federal side of overlapping matters and coordinates with Maryland counsel where state-court litigation is necessary. Many Comptroller disputes resolve at the informal-hearing or Maryland Tax Court stage without ever reaching state court.