Tax Attorney in New York City, NY
Federal IRS representation for taxpayers across all five boroughs — audits, back taxes, liens, levies, payroll-tax disputes, and U.S. Tax Court litigation at 290 Broadway in Foley Square. We coordinate New York State Department of Taxation and Finance matters via Form POA-1 and NYC Department of Finance work via NYC Form POA-2 where they sit alongside a federal case.
Reviewed by Parham Khorsandi, Esq. — California Bar #266658. Last reviewed: .
$91M+
in tax relief secured
2,000+
resolved cases
5.0 / 72
Google reviews
U.S. Tax Court
admitted counsel
If you owe back taxes in New York City, here is the 2026 picture
New York City is one of the only places in the United States where a high-income earner pays three separate income taxes on the same dollar — federal under IRC § 1, New York State graduated personal income tax topping at 10.9% on income above $25 million under NY Tax Law § 601, and the NYC personal income tax of 3.078% to 3.876% layered on top under NYC Administrative Code § 11-1701. The combined New York State plus NYC top marginal rate reaches 14.776% on income earned by a five-borough resident. Stack that on the 37% federal top rate and a JPMorgan managing director, a Goldman Sachs partner, a Wachtell of-counsel attorney, or a Memorial Sloan Kettering department chair can face an effective marginal rate near 52% on every dollar above the threshold. Self-employed Manhattan professionals also pay the NYC Unincorporated Business Tax at 4% under NYC Admin Code § 11-503 — a fourth tax on the same earnings, unique to New York City among American municipalities.
If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the New York State Department of Taxation and Finance has issued a Notice of Determination, or the NYC Department of Finance has docketed an UBT or commercial-rent assessment, the deadlines run fast. We pull your IRS account transcripts, calculate your CSED, file Form 2848 Power of Attorney with the IRS, Form POA-1 with NYS, and a NYC Power of Attorney with the Department of Finance, and put administrative brakes on collection while the case is built.
Federal tax representation for New York City 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 New York at the Daniel Patrick Moynihan United States Courthouse and the Foley Square Federal Building at 290 Broadway. New York is one of the highest-volume U.S. Tax Court trial cities in the country, drawing petitioners from Manhattan, Brooklyn, Queens, the Bronx, Staten Island, Long Island, Westchester, and the lower Hudson Valley. From our Robertson Boulevard office in Los Angeles, we represent New York City residents and entities domiciled across the five boroughs 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 New York State tax matters — the graduated 4% to 10.9% personal income tax under NY Tax Law § 601, the 6.5% (top 7.25%) corporate franchise tax under NY Tax Law § 210, the New York State estate tax with its $7.16 million 2026-indexed exemption under NY Tax Law § 952, the 4% state sales tax under NY Tax Law § 1105, the Metropolitan Commuter Transportation Mobility Tax, and contested matters headed to the New York State Division of Tax Appeals or the New York State Tax Appeals Tribunal — we file Form POA-1 with the Department of Taxation and Finance and handle the administrative track directly. For New York City tax matters — the NYC personal income tax under Admin Code § 11-1701, the NYC Unincorporated Business Tax at 4% under Admin Code § 11-503, the NYC General Corporation Tax, the Commercial Rent Tax for Manhattan tenants south of 96th Street, and the NYC Real Property Transfer Tax — we file a NYC Department of Finance Power of Attorney and engage with the city's audit and collections divisions directly. For formal litigation before the New York State Tax Appeals Tribunal (the independent state-tax tribunal seated at Agency Building 1, 6th Floor, in Albany under NY Tax Law § 170 et seq.) or in the New York Supreme Court Tax Term, we refer to locally admitted New York counsel under a co-counsel arrangement. The federal layer is where most New York City Wall Street, Big Law partner, and equity-compensation cases live, and that is where our engagement carries the load.
New York City sits at the center of the most concentrated high-income economy in the country. Wall Street and the Financial District hold the densest cluster of investment banks, asset managers, private-equity firms, and hedge funds in the world: JPMorgan Chase, Goldman Sachs, Morgan Stanley, Citigroup, Bank of America, Wells Fargo, Merrill Lynch, Lazard, Evercore, Centerview, Moelis, Blackstone, KKR, Apollo, Carlyle, Pershing Square, Citadel, D.E. Shaw, Two Sigma, Renaissance Technologies, and Brookfield Asset Management. Add the Manhattan Big Law corridor — Wachtell, Cravath, Skadden, Sullivan & Cromwell, Davis Polk, Cleary Gottlieb, Simpson Thacher, Latham, Paul Weiss, Kirkland, Quinn Emanuel, Weil, Debevoise, Proskauer, Milbank, Cadwalader, and Shearman & Sterling — alongside the Big Four (Deloitte, EY, PwC, KPMG), the Hudson Yards and Chelsea tech offices of Google, Meta, Amazon, Apple, Microsoft, Bloomberg, Spotify, Squarespace, and Etsy, the media and publishing concentration around Times Square and Midtown (NYT, WSJ News Corp, Bloomberg LP, Penguin Random House, HarperCollins, Hachette, Macmillan, Simon & Schuster, Time, Vanity Fair, The New Yorker), the Mount Sinai, NewYork-Presbyterian, Memorial Sloan Kettering, NYU Langone, Northwell, Montefiore, HSS, and Columbia University Irving Medical Center hospital systems, Columbia, NYU, Fordham, Cornell Tech, The New School, and the CUNY network, the United Nations diplomatic community, the Diamond District at 47th Street, the Garment District, the Brooklyn Navy Yard and Queens industrial corridor, plus the Yankees, Mets, Knicks, Rangers, Nets, Islanders, Giants, Jets, and NYCFC payrolls — and you have a tax-resolution footprint that is essentially RSU and ISO underwithholding, § 83(b) elections, § 1061 three-year carried-interest holding periods for private-equity and hedge-fund partners, § 199A SSTB exclusions blocking QBI for Big Law and Big Four partners, § 1202 Qualified Small Business Stock claims, § 1503 dual-consolidated-loss issues, FBAR work on Israeli, Iranian-Jewish, Russian-Jewish, Chinese, Korean, Vietnamese, Filipino, Indian, Pakistani, Bangladeshi, Dominican, Puerto Rican, Brazilian, Italian, Irish, and Polish family accounts, § 871 and § 1441 nonresident-alien withholding for UN diplomats and treaty-residents, and § 631 NYS sourcing for residents who relocated to Florida or Texas but still earn New York income. The federal procedures are uniform; the facts are New York-specific.
Your tax rights as a New York City taxpayer
Three parallel rights frameworks apply when you owe tax in New York City. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from the New York Tax Law, the Department of Taxation and Finance's published Taxpayer Bill of Rights under NY Tax Law § 3000, and the procedural rules of the New York State Division of Tax Appeals and Tax Appeals Tribunal. City rights come from the NYC Administrative Code Title 11 and the procedural rules of the NYC Department of Finance and the NYC Tax Appeals Tribunal. Knowing all three is the difference between a clean resolution and a missed 90-day Tribunal petition window that locks in a state or city assessment against your Manhattan co-op or Brooklyn brownstone.
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. New York State mirrors this through Form POA-1 accepted by the Department of Taxation and Finance; NYC accepts its own Power of Attorney form for Department of Finance matters.
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 New York at the Foley Square Federal Building, 290 Broadway — one of the highest-volume Tax Court trial cities in the country.
Right to Tax Appeals Tribunal review
NY Tax Law § 2010 gives you 90 days from a final Department of Taxation and Finance Notice of Determination to file a petition with the New York State Division of Tax Appeals, an independent body whose decisions are reviewed by the New York State Tax Appeals Tribunal. The Tribunal sits at Agency Building 1, 6th Floor, W A Harriman State Campus, Albany. Missing the 90-day window forfeits the right to pre-payment review of the state assessment.
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. New York State runs a parallel Offer in Compromise program under NY Tax Law § 171.fifteenth administered by the Department of Taxation and Finance, with similar hardship and insolvency standards. The NYC Department of Finance also accepts compromise offers on NYC tax liabilities. Each program requires 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 New York City 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 New York City taxpayers carrying parallel state or city liabilities, we run a separate New York State Offer in Compromise filing with the Department of Taxation and Finance under NY Tax Law § 171.fifteenth and, where applicable, a NYC Department of Finance compromise offer on the same financial showing — coordinating each program so an accepted federal Offer does not break a pending state or city offer.
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 New York City taxpayers carrying between $50,000 and $250,000 in federal debt, particularly Wall Street associates who underwithheld on RSU vests and Big Law partners whose first K-1 year produced a six-figure surprise. New York State runs a separate twenty-year collection clock under NY Tax Law § 174-b — double the federal CSED — which materially changes the partial-pay arithmetic on the state side.
Lien discharge, subordination, and withdrawal
When a Notice of Federal Tax Lien blocks a New York City property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the City Register's Office encumber title on Manhattan co-ops, Brooklyn brownstones, Queens single-family homes, Bronx multi-family buildings, and Staten Island residences; the IRS procedures under IRC § 6325 set the cure path. New York State tax warrants are docketed in the County Clerk's office under NY Civil Practice Law and Rules § 5018 and operate as a judgment lien against real and personal property. 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. New York State tax warrants are enforced through County Sheriff levies and income executions under NY Tax Law § 174 and the New York CPLR. NYC Department of Finance collections follow a parallel administrative track.
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, § 1061 three-year carried-interest holding periods for Blackstone, KKR, Apollo, Carlyle, and other private-equity and hedge-fund partners, § 199A SSTB exclusions affecting Big Law and Big Four partners over the income threshold, § 174 R&D capitalization timing for Hudson Yards tech, and dual-resident NYS § 631 sourcing disputes for taxpayers who moved to Florida but still work in New York. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. New York trial sessions are held at 290 Broadway in Foley Square.
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. New York State penalties under NY Tax Law § 685 (failure to file) and § 685(p) (substantial understatement) follow a separate reasonable-cause analysis applied by the Department of Taxation and Finance and reviewable by the Division of Tax Appeals. NYC Administrative Code § 11-1717 imposes parallel city-level penalties on personal income tax delinquencies.
Twelve types of New York City tax matters we handle
Federal cases for taxpayers across the five boroughs, framed against the NYS DTF and NYC Department of Finance overlay where it matters.
Wall Street RSU, ISO, and bonus underwithholding
JPMorgan Chase, Goldman Sachs, Morgan Stanley, Citigroup, Bank of America, Wells Fargo, Lazard, Evercore, and Centerview employees hold a mix of RSUs, stock options, and large cash bonuses paid each January. ISO disqualifying dispositions trigger AMT under IRC § 55; § 83(b) elections demand exact 30-day windows; supplemental wage withholding of 22% federal sits far below the actual marginal rate. A single Wall Street bonus cycle, combined with the 10.9% NY State top rate and the 3.876% NYC top rate, can produce a six- or seven-figure federal balance plus a substantial state and city shortfall.
§ 1061 carried-interest holding period for PE and hedge funds
IRC § 1061 imposes a three-year holding period requirement before a carried-interest allocation qualifies for long-term capital-gain treatment. Blackstone, KKR, Apollo, Carlyle, Pershing Square, Citadel, D.E. Shaw, Two Sigma, and Renaissance Technologies partners receive applicable partnership interests that must be tracked deal-by-deal. Failure to satisfy the three-year hold reclassifies the gain as short-term and pulls it into ordinary rates. New York is the capital of the carried-interest practice in the United States.
Big Law and Big Four partner § 199A SSTB exclusion
IRC § 199A excludes specified service trades or businesses — law, accounting, health, consulting, financial services, athletics, performing arts — from the qualified business income deduction once taxable income exceeds the threshold (around $241,950 single / $483,900 joint for 2025, indexed). Wachtell, Cravath, Skadden, Sullivan & Cromwell, Davis Polk, Cleary Gottlieb, Simpson Thacher, Latham, Paul Weiss, Kirkland, and Big Four partners almost universally fall into the excluded SSTB category at their income levels. We defend partner K-1 reporting positions and address the parallel state and NYC UBT exposure.
NYC Unincorporated Business Tax
NYC Admin Code § 11-503 imposes a 4% Unincorporated Business Tax on the self-employment income of sole proprietors, single-member LLCs, and most partnerships doing business in New York City — unique to NYC among American municipalities. Manhattan freelance creatives, consultants, real-estate agents, freelance physicians, Diamond District wholesalers, and Garment District trade businesses all carry steady UBT exposure. The tax is layered on top of federal self-employment tax, the federal income tax, the New York State personal income tax, and the NYC personal income tax — four taxes on the same dollar of self-employment earnings.
New York State estate-tax cliff
NY Tax Law § 952 imposes a graduated New York State estate tax with a 2026-indexed exemption around $7.16 million per estate — well below the $13.61 million federal exemption. The notorious New York cliff rule applies: estates valued at more than 105% of the exemption lose the credit entirely and pay state estate tax from the first dollar. A Manhattan co-op, a Hamptons second home, a retirement account, and life-insurance proceeds can cross the cliff threshold without anyone realizing the full credit has been forfeited. Form ET-706 is due nine months from death.
NYS § 631 nonresident sourcing after relocation
A growing share of post-2020 NYC departures — to Florida, Texas, Nevada, Tennessee — still earn income sourced to New York under NY Tax Law § 631 and the “convenience of the employer” rule. Days worked from a New York employer's office, or at the employee's home for the employer's convenience rather than necessity, remain New York-source income subject to NY State personal income tax. New York audits relocated taxpayers aggressively, especially Wall Street and Big Law professionals whose firms maintain a New York office. Statutory residence under NY Tax Law § 605 also catches taxpayers who keep an apartment in NYC and spend more than 183 days in the state.
Trust Fund Recovery Penalty
IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. NYC restaurant, hospitality, retail, construction, and biotech-startup owners are common targets. The IRS uses Form 4180 interviews to identify responsible persons; New York applies parallel responsible-person rules to withheld state income tax under NY Tax Law § 685(g) and NYC Admin Code § 11-1717 to withheld NYC personal income tax.
Notice of Federal Tax Lien
NFTLs are filed with the City Register's Office for property in Manhattan, the Bronx, Brooklyn, and Queens, and with the Richmond County Clerk for Staten Island. They encumber title and trigger CDP rights under IRC § 6320. New York State tax warrants under NY Tax Law § 174 are docketed with the County Clerk and operate as judgment liens. Manhattan co-op transfers, Brooklyn brownstone sales, Queens single-family closings, Bronx multi-family refinances, and Staten Island residential closings stall fast when a lien hits the title search.
IRS bank or wage levy
Bank levies on accounts held at JPMorgan Chase, Citi, Bank of America, Wells Fargo, Capital One, Apple Bank, Signature Bank, M&T, Flushing Bank, or any New York-chartered institution. Wage levies hit NYC employers within days of CP90 or LT11 issuance — including Wall Street firms, Big Law firms, Big Four firms, the Hudson Yards tech offices, Mount Sinai, NewYork-Presbyterian, Memorial Sloan Kettering, NYU Langone, and Columbia.
FBAR and FATCA non-disclosure
FinCEN Form 114 for foreign accounts over $10,000 aggregate. New York City holds the largest concentration of FBAR exposure in the United States: Israeli expat, Iranian-Jewish (Great Neck, Manhattan, Brooklyn), Russian-Jewish (Brighton Beach), Hasidic and Orthodox Jewish (Borough Park, Williamsburg, Crown Heights, Riverdale), Chinese (Manhattan and Flushing Chinatown), Korean (Flushing), Vietnamese (Sunset Park), Filipino (Queens), Indian (Jackson Heights), Pakistani (Brooklyn), Bangladeshi (Jamaica), Dominican (Washington Heights), Brazilian (Astoria), Italian (Bensonhurst), Irish (Inwood), and Polish (Greenpoint) communities all carry steady FBAR exposure on overseas accounts. The IRS Streamlined Filing Compliance Procedures are a frequent engagement.
UN diplomatic and nonresident-alien tax
United Nations Headquarters on First Avenue produces a steady book of diplomatic-tax matters. IRC § 893 exempts certain foreign-government employees from U.S. income tax; IRC § 871 governs nonresident-alien taxation; IRC § 1441 governs treaty-based withholding. Mission staff, treaty traders, exchange visitors, and dual-status residents all need close coordination on the substantial-presence test, treaty tie-breakers, and Form 1040-NR versus Form 1040 elections.
Cryptocurrency, royalty, and 1099 reporting
CP2000 notices on unreported digital-asset gains, basis-tracking failures, and DeFi-protocol income. Form 1099-DA reporting (effective 2025) drives the matching cases. New York City's media and publishing concentration produces a steady volume of book-royalty (NY Times, Penguin Random House, HarperCollins, Hachette, Macmillan, Simon & Schuster), composer-royalty, actor 1099, and freelance writer assessments. New York treats royalty income as ordinary income subject to the 4%-10.9% graduated state rate and the additional NYC personal income tax for residents.
Nine common causes of tax debt for New York City taxpayers
Patterns we see repeatedly in NYC-based engagements. None of them are unusual — all of them are resolvable.
1. Underwithheld Wall Street bonus and RSU vest
A Goldman Sachs, JPMorgan, Morgan Stanley, Citi, BofA, or Blackstone employee at the 35% or 37% federal bracket sees only 22% supplemental withholding on the January bonus and on quarterly RSU vests. The shortfall, plus 10.9% NYS at the top bracket and 3.876% NYC, produces a six-figure balance due the following April.
2. Self-employment and UBT underpayment
Manhattan attending physicians with side practices, Big Law of-counsel attorneys, consultants in the Madison Avenue advertising corridor, freelance writers for NYT/WSJ/New Yorker, Bushwick and Chelsea gallery artists, and real-estate agents 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, on top of the NYC UBT under Admin Code § 11-503.
3. Business closure
When an LLC, S-corp, or early-stage NYC startup closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Common in the Manhattan and Brooklyn restaurant cycle and the Hudson Yards startup-failure pattern.
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 — common in NYC high-income divorces where one spouse's K-1 carry, partner draw, or RSU vest surprised the other.
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. The NYS DTF and NYC Department of Finance each run their own identity-theft units that operate in parallel.
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. New York treats digital-asset gains as taxable income at the full state and city graduated rates.
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. New York mirrors the federal three-year refund bar under NY Tax Law § 687.
8. Real-estate sale without estimated tax
A Manhattan co-op, Brooklyn brownstone, Queens single-family, or Hamptons second-home sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Investor flips are taxed at ordinary-income rates — not capital-gain — under the dealer-status rules of IRC § 1221. The NYC Real Property Transfer Tax under Admin Code § 11-2102 and the NYS “mansion tax” on residential sales above $1 million add city and state layers.
9. Stock-option exercise without planning
ISO disqualifying dispositions and NSO ordinary-income inclusions hit NYC Wall Street, tech, biotech, and financial-services employees with AMT under IRC § 55 and large balances due. IRC § 83(b) elections missed within the 30-day window create their own irreversible problem — particularly costly for Hudson Yards tech founders whose early-grant basis was low and whose § 1202 QSBS holding period depends on a valid election.
Eight tax liabilities that pull in New York City taxpayers
Federal authority alongside the New York State and NYC Administrative Code parallels.
Failure to file federal return
IRC § 6651(a)(1) imposes 5% per month, capped at 25%, plus interest under IRC § 6601. The New York mirror is NY Tax Law § 685(a)(1) imposing 5% per month, capped at 25%, on unpaid New York State personal income tax. NYC Admin Code § 11-1717 applies parallel additions to NYC personal income tax.
Failure to file New York State return
NY Tax Law § 685(a) imposes a 5% per month penalty on unpaid New York tax for failure to file, capped at 25%, plus interest under NY Tax Law § 684. The Department of Taxation and Finance may issue a Notice of Determination triggering the 90-day Tax Appeals Tribunal petition window under NY Tax Law § 2010. Statutory residence under NY Tax Law § 605 captures taxpayers who maintain a permanent place of abode in New York and spend more than 183 days in the state.
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.
New York and NYC sales-tax delinquency
The combined NYC sales-tax rate is 8.875%: 4% New York State (NY Tax Law § 1105), 4% NYC, and 0.375% MCTD surcharge. NY Tax Law § 685(g) imposes personal liability on responsible persons for unpaid trust-fund sales tax — one of the most aggressively enforced state-tax regimes in the country. Use-tax assessments under NY Tax Law § 1110 target businesses purchasing equipment from out of state without paying use tax on the bring-in.
Trust Fund Recovery Penalty
IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. New York applies parallel responsible-person rules to withheld state income tax under NY Tax Law § 685(g) and to withheld NYC personal income tax under NYC Admin Code § 11-1717.
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. NY Tax Law § 685(p) imposes a parallel 10% to 20% New York accuracy-related penalty on substantial understatements.
New York State estate tax with cliff
NY Tax Law § 952 imposes the New York estate tax on estates above the 2026-indexed exemption of approximately $7.16 million, with a graduated rate scale topping out at 16%. The cliff rule applies: estates valued at more than 105% of the exemption lose the credit entirely and pay state estate tax from the first dollar — a feature unique to New York among estate-tax states. Form ET-706 is filed within nine months of death. Coordination with the federal Form 706 estate-tax return is its own engagement layer.
NYC Unincorporated Business Tax
NYC Admin Code § 11-503 imposes a 4% tax on the unincorporated business income of sole proprietors, single-member LLCs, and partnerships doing business in New York City. The tax applies even when the proprietor lives outside the five boroughs, so long as the business activity is sourced to NYC. Audit selection runs heavy on professional-service taxpayers (consultants, freelance creatives, real-estate agents, freelance physicians).
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 City Register's Office.
Sample tax-resolution outcomes
Anonymized client matters drawn from our $91M+ 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, the New York State Department of Taxation and Finance, and the NYC Department of Finance.
Why Victory Tax Lawyers for a New York City federal-tax case
Victory Tax Lawyers is California-Bar-admitted, not New York-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 New York at the Foley Square Federal Building, 290 Broadway. 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 New York City clients never need a separately admitted New York attorney because the case is, at its core, federal.
For administrative work before the New York State Department of Taxation and Finance — protests, audit responses, Offer in Compromise submissions under NY Tax Law § 171.fifteenth, and installment-agreement requests — we file Form POA-1 and handle the matter remotely. For NYC Department of Finance matters — UBT audits under NYC Admin Code § 11-503, General Corporation Tax assessments, Commercial Rent Tax exposure for Manhattan tenants south of 96th Street, NYC personal income tax disputes, and NYC Real Property Transfer Tax claims — we file a NYC Department of Finance Power of Attorney and engage with the city's audit and collections divisions directly. When a case must move to the New York State Division of Tax Appeals or the New York State Tax Appeals Tribunal (the independent state-tax tribunal seated at Agency Building 1, 6th Floor, in Albany under NY Tax Law § 170 et seq.) or appeal further to the Appellate Division, Third Department, we coordinate with locally admitted New York counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure given New York's 10.9% top state rate plus 3.876% NYC rate stacked on a 37% federal top, 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 $91M+ in cumulative tax relief secured across 2,000+ resolved matters. No marketing claim of being a New York-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any New York City 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 New York City 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, POA-1, and NYC PoA
We file the federal Power of Attorney with the IRS, Form POA-1 with the New York State Department of Taxation and Finance, and a Power of Attorney with the NYC Department of Finance where city tax is at issue, then step in as the contact of record on each agency.
Transcript and CSED analysis
We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events. The parallel twenty-year NYS collection clock under NY Tax Law § 174-b is mapped on the same chart.
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, a NYS DTA petition through local counsel, or a NYC Tax Appeals Tribunal petition — and handle every IRS, NYS, and NYC contact.
Compliance monitoring
After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, and prevent default.
Three collection clocks: federal CSED, New York's twenty-year statute, and NYC enforcement
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.
New York State runs a markedly longer collection rule under NY Tax Law § 174-b: the Department of Taxation and Finance generally has twenty years from the date of the docketed tax warrant to collect, with renewal possible. That is double the federal CSED and one of the longest collection statutes in the country. NYC Department of Finance collections on UBT, NYC personal income tax, and General Corporation Tax follow the same warrant-based docketing system under the NYC Administrative Code, with similarly long enforcement periods. Many New York City taxpayers carry a federal CSED that will run out a decade before the New York State warrant clock expires. Pull all three records and know all three timelines before agreeing to any payment plan or amended return that could restart a clock.
New York City tax authorities and venues
A working knowledge of the tribunals, agencies, and field offices in New York City is what separates an answered Notice from a wage levy or a docketed tax warrant. Below is the working list our firm uses on every NYC matter.
Internal Revenue Service — Manhattan TAC
The federal tax authority, at irs.gov. The Manhattan Taxpayer Assistance Center operates at the Foley Square Federal Building, 290 Broadway, 7th Floor, New York NY 10007. The Brooklyn TAC operates at 625 Fulton Street, 6th Floor, Brooklyn NY 11201. Appointments required.
U.S. Tax Court — New York trial sessions
The U.S. Tax Court holds regular trial sessions in New York at the Foley Square Federal Building, 290 Broadway. New York is one of the highest-volume Tax Court trial cities in the country, drawing petitioners from Manhattan, Brooklyn, Queens, the Bronx, Staten Island, Long Island, Westchester, and the lower Hudson Valley. Petitions are filed at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).
New York State Department of Taxation and Finance
The state tax authority, at tax.ny.gov. Headquartered at the W A Harriman State Campus, Albany NY 12227, with downstate offices including 350 Brookfield Place in Manhattan and the Adam Clayton Powell Jr. State Office Building at 163 W 125th Street in Harlem. Administers the graduated 4%-10.9% personal income tax under NY Tax Law § 601, the 6.5%-7.25% corporate franchise tax under NY Tax Law § 210, the 4% state sales-and-use tax under NY Tax Law § 1105, withholding tax, the Metropolitan Commuter Transportation Mobility Tax, the New York State estate tax under NY Tax Law § 952, and the Offer in Compromise program under NY Tax Law § 171.fifteenth.
New York State Tax Appeals Tribunal
The independent state-tax tribunal under NY Tax Law § 170 et seq., seated at Agency Building 1, 6th Floor, W A Harriman State Campus, Albany NY 12223. Reviews determinations of the New York State Division of Tax Appeals. Hears disputes between taxpayers and the New York State Department of Taxation and Finance covering personal income, corporate franchise, sales, estate, MCTMT, and related state taxes. The 90-day petition deadline runs from a final Notice of Determination under NY Tax Law § 2010. Tribunal decisions are appealable to the Appellate Division, Third Department.
NYC Department of Finance
The municipal finance authority for the City of New York, headquartered at 1 Centre Street, 22nd Floor, Manhattan NY 10007. Page: nyc.gov/finance. Administers NYC personal income tax under NYC Admin Code § 11-1701, the Unincorporated Business Tax under Admin Code § 11-503, the General Corporation Tax, the Commercial Rent Tax for Manhattan tenants south of 96th Street, the Real Property Transfer Tax under Admin Code § 11-2102, property-tax collection, and the NYC Tax Court Office of Conciliation. NFTLs and NYS warrants affecting NYC-located property are recorded with the City Register's Office for Manhattan, Brooklyn, Queens, and the Bronx, and with the Richmond County Clerk for Staten Island.
U.S. District Court — Southern District of New York
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.N.Y.) at the Daniel Patrick Moynihan United States Courthouse, 500 Pearl Street, New York NY 10007, or in the U.S. Court of Federal Claims in Washington, D.C.
U.S. District Court — Eastern District of New York
Federal tax refund suits arising from Brooklyn, Queens, Staten Island, Long Island, and Nassau or Suffolk counties may be filed in the Eastern District of New York at the Theodore Roosevelt United States Courthouse, 225 Cadman Plaza East, Brooklyn NY 11201.
IRS Independent Office of Appeals
The administrative-appeals body within the IRS that resolves cases without litigation. NYC cases run through the Appeals offices serving the metropolitan region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.
Taxpayer Advocate Service — New York
An independent organization within the IRS that helps when normal channels stall. The New York Local Taxpayer Advocate offices serve taxpayers across all five boroughs and the wider metropolitan region. Page: taxpayeradvocate.irs.gov.
County Clerks and the City Register's Office
The recording offices for Notices of Federal Tax Lien and New York State tax warrants affecting real property in New York City. The Office of the City Register covers New York County (Manhattan), Kings County (Brooklyn), Queens County, and Bronx County; the Richmond County Clerk covers Staten Island. NFTL recording on the wrong borough registry can fail to attach to title — a procedural defect that can be the basis of a lien-withdrawal request under Form 12277.
Speak with a tax attorney about your New York City matter
Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, a NYS Notice of Determination, or a NYC Department of Finance assessment is in front of you, the deadline to respond is real and short — call today.
Frequently asked questions — New York City tax
What is the combined New York State and NYC top tax rate?
The New York State graduated personal income tax under NY Tax Law § 601 tops out at 10.9% on taxable income above $25 million for the 2026 tax year. The New York City personal income tax under NYC Administrative Code § 11-1701 imposes an additional 3.078% to 3.876% on five-borough residents. The combined New York State plus NYC top marginal rate reaches 14.776% on each dollar above the highest state bracket — one of the highest sub-national tax burdens in the United States. The combined rate sits on top of the 37% federal top rate plus the 3.8% net-investment-income tax under IRC § 1411, producing an effective marginal rate near 52% for a Wall Street managing director or Big Law partner.
What is the NYC Unincorporated Business Tax and who pays it?
The NYC Unincorporated Business Tax (UBT) under NYC Admin Code § 11-503 is a 4% tax on the unincorporated business income of sole proprietors, single-member LLCs, and most partnerships doing business in New York City — unique to NYC among American municipalities. Manhattan and Brooklyn freelance creatives, consultants, real-estate agents, freelance physicians, Big Law of-counsel attorneys filing 1099 income, Diamond District wholesalers, Garment District trade businesses, Bushwick and Chelsea gallery artists, and most owner-operated NYC businesses carry steady UBT exposure. The first $95,000 of UBT income is generally exempt, and a sliding-scale credit applies up to $150,000; above that the full 4% applies. The tax is layered on top of federal self-employment tax, the federal income tax, the New York State personal income tax, and the NYC personal income tax.
Where is the closest U.S. Tax Court trial location to New York City?
The U.S. Tax Court holds regular trial sessions in New York City itself at the Foley Square Federal Building, 290 Broadway. New York is one of the highest-volume Tax Court trial cities in the country — petitioners from Manhattan, Brooklyn, Queens, the Bronx, Staten Island, Long Island, Westchester, and the lower Hudson Valley request the New York trial location when filing. 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 New York State Tax Appeals Tribunal and what is its deadline?
The New York State Tax Appeals Tribunal is the independent state-tax tribunal established under NY Tax Law § 170 et seq. It sits at Agency Building 1, 6th Floor, W A Harriman State Campus, Albany NY 12223. The Tribunal reviews determinations of the New York State Division of Tax Appeals, which hears disputes between taxpayers and the New York State Department of Taxation and Finance covering personal income tax, corporate franchise tax, sales tax, estate tax, MCTMT, and related state taxes. The petition deadline is 90 days from a final Notice of Determination under NY Tax Law § 2010 — the same length as the federal Tax Court window. Tribunal decisions are appealable to the Appellate Division, Third Department. Victory Tax Lawyers refers Tax Appeals Tribunal litigation to locally admitted New York counsel; we handle the federal portion and the NYS DTF administrative work directly.
What is New York's collection statute of limitations?
New York State runs a markedly longer collection statute than the federal CSED. Under NY Tax Law § 174-b, the New York State Department of Taxation and Finance generally has twenty years from the date of the docketed tax warrant to collect, with renewal possible on continuing nonpayment. That is double the federal IRC § 6502 ten-year CSED and one of the longest state collection statutes in the country. NYC Department of Finance collections on UBT, NYC personal income tax, and General Corporation Tax follow the same warrant-based docketing system under the NYC Administrative Code with similarly extended enforcement periods. Coordinated case planning hinges on knowing all three timelines before any action that could restart a clock.
I moved from New York to Florida — do I still owe New York income tax?
Possibly yes. New York State taxes nonresidents on income sourced to New York under NY Tax Law § 631, and the “convenience of the employer” rule treats days worked from your Florida home as New York-source income when the work was performed for the convenience of the employee rather than the necessity of the employer. New York Wall Street, Big Law, Big Four, and Hudson Yards tech firms that maintain a New York office generally do not satisfy the necessity exception. Statutory residence under NY Tax Law § 605 also applies if you maintain a permanent place of abode in New York and spend more than 183 days in the state during the year — keeping a pied-a-terre in Manhattan plus regular work travel can pull a Florida-domiciled taxpayer back into full New York residency for the year. New York audits relocated high-income taxpayers aggressively, and the NYS DTF maintains a dedicated nonresident audit program. We address both NY State and NYC residency exposure on the federal track.
Can I be audited by the IRS, NYS DTF, and the NYC Department of Finance for the same year?
Yes. The IRS, the New York State Department of Taxation and Finance, and the NYC Department of Finance operate independently and share information through the IRS-state exchange program and through NY Tax Law § 211 federal-change reporting. A federal audit adjustment is routinely reported to New York, and a New York audit adjustment is routinely reported to NYC. We coordinate the three audits to prevent inconsistent positions on the federal record from costing you on the state and city returns — particularly important on UBT, where a federal Schedule C reclassification automatically reopens the city assessment.
Does New York have an Offer in Compromise equivalent to the federal program?
Yes. The New York State Department of Taxation and Finance accepts Offers in Compromise under NY Tax Law § 171.fifteenth. The Department considers offers based on doubt as to collectibility, doubt as to liability, and undue economic hardship — standards that parallel federal IRC § 7122 analysis but with state-specific procedural rules and a separate disclosure package. All New York returns must be filed before consideration, current-year withholding and estimated-tax compliance is verified, and a financial-disclosure package is required. The NYC Department of Finance accepts parallel compromise offers on NYC tax liabilities. We typically run a state and city Offer in parallel with the federal Offer where all three debts are real.
I work in private equity or a hedge fund — how does § 1061 carried interest apply?
IRC § 1061 imposes a three-year holding period before a carried-interest allocation qualifies for long-term capital-gain treatment. An applicable partnership interest held for less than three years produces short-term gain taxed at ordinary federal rates — up to 37% — instead of the 20% long-term capital-gain rate. New York City is the capital of the carried-interest practice: Blackstone, KKR, Apollo, Carlyle, Pershing Square, Citadel, D.E. Shaw, Two Sigma, and Renaissance Technologies partners receive applicable partnership interests that must be tracked deal-by-deal. Documentation of each deal's transfer date and disposition date is critical. New York State and NYC tax the partner's distributive share at the full graduated state and city rates regardless of federal character.
I'm a Big Law or Big Four partner — do I qualify for the § 199A QBI deduction?
Generally no. IRC § 199A excludes specified service trades or businesses — law, accounting, health, consulting, financial services, athletics, performing arts — from the qualified business income deduction once taxable income exceeds the threshold (approximately $241,950 single / $483,900 joint for 2025, indexed). A Wachtell, Cravath, Skadden, Sullivan & Cromwell, Davis Polk, Cleary Gottlieb, Simpson Thacher, Paul Weiss, Kirkland, Latham, Quinn Emanuel, Weil, Debevoise, Proskauer, or Milbank partner almost universally falls into the excluded SSTB category at the income level required for partnership equity. The same applies to Deloitte, EY, PwC, and KPMG partners. We defend partner K-1 reporting positions and confirm whether any non-SSTB activity (e.g., a separate real-estate partnership) supports a partial QBI claim, and we address the parallel state and NYC UBT exposure.
Can a California-Bar-admitted attorney represent me in New York City?
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 New York. For New York State Department of Taxation and Finance administrative work, we file Form POA-1 and handle the matter remotely. For NYC Department of Finance work, we file a NYC Power of Attorney and engage the city's audit and collections divisions directly. For formal litigation before the New York State Tax Appeals Tribunal or a Supreme Court Tax Term proceeding, we co-counsel with locally admitted New York 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). New York follows a parallel filing-compliance posture under NY Tax Law § 683; the Department may assess based on federal-change reporting under NY Tax Law § 211 or estimate tax when a taxpayer fails to file. NYC Department of Finance enforcement parallels the state track.
Can the IRS levy my New York 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 JPMorgan Chase, Citi, Bank of America, Wells Fargo, Capital One, Apple Bank, Signature Bank, M&T, Flushing Bank, or any New York-chartered institution and serve wage levies on NYC employers including Wall Street firms, Big Law firms, Big Four firms, Mount Sinai, NewYork-Presbyterian, Memorial Sloan Kettering, NYU Langone, Columbia, and any Hudson Yards tech employer. 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). New York State tax warrants are enforced through County Sheriff levies and income executions under NY Tax Law § 174 and the New York CPLR.
A family member died in New York — do I owe state estate tax?
Possibly yes, and the New York cliff rule may multiply the bill. NY Tax Law § 952 imposes the New York estate tax on estates above the 2026-indexed exemption of approximately $7.16 million per decedent, with a graduated rate scale topping out at 16%. The notorious cliff rule under NY Tax Law § 952(c)(2): if an estate is valued at more than 105% of the exemption, the credit is lost entirely and state estate tax is owed from the first dollar — not just on the excess. A Manhattan co-op, a Hamptons or Westchester second home, retirement accounts, and life-insurance proceeds can cross the 105% threshold and forfeit the full credit without anyone realizing. Form ET-706 is due nine months from death. 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 New York State Offer in Compromise under NY Tax Law § 171.fifteenth typically runs six to twelve 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. New York State and NYC collections follow a similar pattern: a Form POA-1 routes NYS DTF contact and a NYC Power of Attorney routes Department of Finance contact, and a pending state or city Offer pauses tax-warrant 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 $91 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 New York statute citation references the New York Tax Law and the NYC Administrative Code. 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 New York State Department of Taxation and Finance, the NYC Department of Finance, the U.S. Tax Court, the New York State Tax Appeals Tribunal, 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 New York; where a New York state-court appearance or New York State Tax Appeals Tribunal 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.
Related practice areas
Offer in Compromise
IRC § 7122 settlements
Installment Agreement
IRC § 6159 payment plans
Tax Lien Help
NFTL release and discharge
Tax Levy Defense
IRC § 6343 release
Audit Representation
IRS examinations
Penalty Abatement
IRC § 6651 relief
Back Taxes
Unfiled-return resolution
New York state hub
Statewide NY practice
See other areas
All areas we serve
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. § 1202 — Qualified Small Business Stock
- 26 U.S.C. § 1061 — Carried-Interest Holding Period
- 26 U.S.C. § 199A — Qualified Business Income / SSTB Exclusion
- 26 U.S.C. § 871 — Nonresident Alien Taxation
- 26 U.S.C. § 893 — Foreign Government Employee Exemption
- 26 U.S.C. § 1411 — Net Investment Income Tax
- 26 U.S.C. § 83 — Property Transferred for Services / 83(b) Election
- NY Tax Law § 601 — New York State graduated personal income tax (4%-10.9%)
- NY Tax Law § 605 — New York statutory residence (183-day rule)
- NY Tax Law § 631 — New York nonresident sourcing
- NY Tax Law § 210 — New York corporate franchise tax
- NY Tax Law § 952 — New York State estate tax (cliff rule)
- NY Tax Law § 1105 — New York State sales tax
- NY Tax Law § 170 et seq. — New York State Tax Appeals Tribunal
- NY Tax Law § 171.fifteenth — New York Offer in Compromise
- NY Tax Law § 174 — New York State tax warrants
- NY Tax Law § 174-b — New York twenty-year collection statute
- NY Tax Law § 211 — New York federal-change reporting
- NY Tax Law § 685 — New York additions to tax and penalties
- NY Tax Law § 2010 — New York Tax Appeals Tribunal petition deadline
- NYC Admin Code § 11-503 — NYC Unincorporated Business Tax
- NYC Admin Code § 11-1701 — NYC personal income tax
- NYC Admin Code § 11-1717 — NYC withholding and responsible-person liability
- NYC Admin Code § 11-2102 — NYC Real Property Transfer Tax