Tax Attorney in Newark, NJ

Federal IRS representation for Newark residents and Essex County businesses — audits, back taxes, liens, levies, payroll-tax disputes, airline-crew 49 U.S.C. § 40116 multi-state allocation for Newark Liberty International Airport (EWR) United pilots and flight attendants, Prudential Financial executive RSU and § 409A exposure, Port Newark-Elizabeth maritime payroll-tax matters, Ironbound Portuguese-American FBAR cleanup, and U.S. Tax Court litigation at the Newark trial location (970 Broad Street). We also coordinate New Jersey Division of Taxation matters under Form M-5008-R Power of Attorney where they sit alongside a federal case.

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

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Serving Newark, the Ironbound, Down Neck, Forest Hill, Weequahic, Vailsburg, the Central Ward, North Ward, South Ward, East Ward, West Ward, and the wider Essex County region

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

New Jersey runs a graduated personal income tax from 1.4% to 10.75% under N.J.S.A. 54A:2-1, with the 10.75% top bracket the third-highest state income tax in the United States after California and Hawaii. The Corporation Business Tax under N.J.S.A. 54:10A-5 sits at 11.5% — among the highest combined federal-plus-state corporate rates in the country once the 21% federal rate is layered on. The state sales tax is 6.625% under N.J.S.A. 54:32B-3, with a reduced 3.3125% Urban Enterprise Zone rate applying to qualified businesses in designated parts of Newark — one of the few major New Jersey cities where the UEZ program survived the 2017 sunset and was reinstated in the 2021 statewide UEZ extension.

Newark carries dimensions that no other New Jersey city carries together. It is the home of Newark Liberty International Airport (EWR) — a United Airlines hub and the busiest airport in New Jersey — which places a working population of pilots, flight attendants, and crew members under the multi-state-allocation rules of 49 U.S.C. § 40116, where wages earned in flight are sourced to the state of residence rather than the state of the flight path. It is the headquarters of Prudential Financial, the Fortune 50 insurer at 751 Broad Street, with the executive RSU, ISO, and IRC § 409A deferred-compensation exposure that comes with a top-50 American corporation. It is the home of Port Newark-Elizabeth, the third-busiest container port on the U.S. East Coast, which brings dockworker, customs-broker, and international-shipping payroll-tax matters. And it is twelve miles west of Lower Manhattan, with NJ Transit, PATH (from Newark Penn Station), and Newark Airport-area transit putting a substantial portion of the workforce in the New York City commuter pool subject to N.Y. Tax Law § 631 nonresident PIT and the New York convenience-of-the-employer rule.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the New Jersey Division of Taxation has issued a Notice of Deficiency or a Final Determination, the deadline to act is short. We pull your IRS account transcripts, calculate your CSED, file Form 2848 Power of Attorney with the IRS and Form M-5008-R with the New Jersey Division of Taxation, and put administrative brakes on collection while the case is built.

Federal tax representation for Newark 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 at the Newark location (970 Broad Street, 14th Floor, in the Martin Luther King Jr. Federal Building) and at the Foley Square location in Manhattan (290 Broadway, twelve miles east). From our Robertson Boulevard office in Los Angeles, we represent Newark residents and Essex-County-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 New Jersey state tax matters — the 1.4% to 10.75% graduated personal income tax under N.J.S.A. 54A:2-1, the 11.5% Corporation Business Tax under N.J.S.A. 54:10A-5, the 6.625% state sales tax under N.J.S.A. 54:32B-3, withholding-tax assessments under N.J.S.A. 54A:7-1, the New Jersey Business Alternative Income Tax (BAIT) elective pass-through entity tax under N.J.S.A. 54A:12-1 et seq., and the New Jersey inheritance tax under N.J.S.A. 54:34-1 et seq. — we file Form M-5008-R Appointment of Taxpayer Representative with the Division of Taxation and handle the administrative track directly. For formal litigation in the New Jersey Tax Court (the state's specialized tax tribunal seated at the Richard J. Hughes Justice Complex in Trenton, 55 miles southwest of Newark) or in the New Jersey Superior Court Appellate Division, we refer to locally admitted New Jersey counsel under a co-counsel arrangement. The federal layer is where most Newark airline-crew, Prudential executive, port-payroll, and Portuguese-American FBAR cases live, and that is where our engagement carries the load.

Newark sits at an unusual intersection. It is the largest city in New Jersey by population (roughly 310,000) and the seat of Essex County, with a corporate ecosystem that pairs Fortune 50 financial services (Prudential at 751 Broad Street, PSEG — Public Service Enterprise Group — at 80 Park Plaza, Audible at 1 Washington Street as an Amazon subsidiary running the audiobook business out of Newark, and Verizon-heavy New Jersey operations) with academic anchors (Rutgers University-Newark including Rutgers School of Law-Newark, Rutgers Business School-Newark, Rutgers New Jersey Medical School at 185 South Orange Avenue, Rutgers School of Dental Medicine, New Jersey Institute of Technology at 323 Martin Luther King Jr. Boulevard, Essex County College, Bloomfield College, and Seton Hall University Law School on Newark's downtown campus). The health-system layer adds Newark Beth Israel Medical Center, University Hospital, and Saint Michael's Medical Center. The Ironbound neighborhood east of Penn Station carries the largest per-capita Portuguese-American population in the United States (rivaled only by Providence, Rhode Island), with an overlapping Brazilian-American population that produces a distinctive FBAR and Streamlined Filing client base. Newark's African-American, Puerto Rican, Dominican, Cuban, Colombian, and Italian-American communities each layer on their own tax-filing patterns. The city's post-1967 urban-revitalization arc — corporate relocation incentive packages, the Prudential Tower buildout in 2015, the Audible-Amazon headquarters expansion, and the Newark Renaissance development corridor — produces a workforce that ranges from W-2 corporate executives to 1099 gig drivers serving the airport.

Your tax rights as a Newark 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 New Jersey Taxpayer Bill of Rights at N.J.S.A. 54:1-2.1 and the procedural rules at N.J.S.A. 54:49-1 et seq. Knowing both is the difference between a clean resolution and a missed 90-day New Jersey Tax Court appeal window that ends in a Certificate of Debt docketed against your Forest Hill, Ironbound, Weequahic, or Vailsburg 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. New Jersey mirrors this through Form M-5008-R Appointment of Taxpayer Representative, accepted by the Division of Taxation for all administrative tax 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 Newark at 970 Broad Street, 14th Floor (the Martin Luther King Jr. Federal Building) and at Foley Square in Manhattan (290 Broadway).

Right to New Jersey Tax Court review

N.J.S.A. 54:51A-14 gives you 90 days from a Final Determination of the Director of the Division of Taxation to file a complaint in the New Jersey Tax Court — the state's specialized tax tribunal seated at the Richard J. Hughes Justice Complex, 25 Market Street, 7th Floor, Trenton NJ 08611, about 55 miles southwest of Newark. The 90-day window aligns with the federal Tax Court deadline. Missing it forfeits the right to pre-payment judicial review.

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.

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 Jersey runs a parallel Closing Agreement program under N.J.S.A. 54:53-1 with similar hardship and insolvency standards, including the Division's Closing Agreement Application for individual and business tax liabilities. Both programs 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 Newark 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 Newark taxpayers, a federal OIC does not resolve New Jersey state liability; we run a parallel Closing Agreement Application with the Division of Taxation under N.J.S.A. 54:53-1 where the state debt is real.

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 Newark taxpayers carrying between $50,000 and $250,000 in federal debt, including Prudential Financial executives with deferred RSU vest events that caught up after a year of high-bracket vesting and United Airlines pilots based at EWR whose multi-state crew-source allocation got out of sync with quarterly estimated-tax payments.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Newark property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Essex County Register of Deeds and Mortgages encumber title on Ironbound, Forest Hill, Weequahic, Vailsburg, North Ward, South Ward, East Ward, West Ward, Central Ward, and Down Neck homes; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing.

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 Jersey state tax liens follow a parallel track: the Division dockets a Certificate of Debt under N.J.S.A. 54:49-12 with the Superior Court Clerk, which functions as a state-court judgment lien on real property in the county where docketed.

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, Prudential and Audible executive RSU and ISO underwithholding, 49 U.S.C. § 40116 airline-crew wage-source disputes, customs-broker IRC § 7202 trust-fund employment-tax matters tied to Port Newark-Elizabeth, and Portuguese-Brazilian FBAR non-disclosure cleanups. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Trial sessions are held at Newark (970 Broad Street) or Foley Square (290 Broadway, Manhattan).

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 Jersey penalties under N.J.S.A. 54:49-4 and N.J.S.A. 54:49-6 follow a separate reasonable-cause analysis applied by the Division and reviewable by the New Jersey Tax Court.

Twelve types of Newark tax matters we handle

Federal cases for Newark residents and businesses, framed against the New Jersey Division of Taxation and New York nonresident-PIT overlays where they matter.

Newark Liberty (EWR) airline-crew 49 U.S.C. § 40116

Newark Liberty International Airport is a United Airlines hub and the busiest commercial airport in New Jersey. Under 49 U.S.C. § 40116(f), wages paid to airline pilots, flight attendants, and crew members for service in flight are sourced to the state of residence and to states where the employee earns more than 50% of compensation — a federal preemption of ordinary multi-state apportionment. A United pilot based at EWR who lives in New Jersey is taxed only by New Jersey on flight-pay even when the routes touch California, Texas, Florida, and abroad; but a pilot who lives in Pennsylvania and bases at EWR can have a residency-audit problem if the New Jersey domicile facts shift. We resolve the underlying base-of-operations and residency analysis and clean up multi-year withholding mismatches.

Prudential Financial executive RSU, ISO, and § 409A

Prudential Financial, headquartered at 751 Broad Street in Prudential Tower, is a Fortune 50 insurance and asset-management company with a senior-executive workforce holding restricted stock units, incentive stock options, and IRC § 409A nonqualified deferred-compensation balances. RSU vest events are taxed at the 22% federal supplemental withholding rate — well below the actual marginal rate for executives at the 35% or 37% bracket. ISO disqualifying dispositions trigger AMT under IRC § 55. § 409A election timing and distribution events at Prudential's deferred-comp plans produce penalty exposure on any misalignment with the 12-month-and-five-year deferral safe harbor.

Port Newark-Elizabeth maritime payroll and customs IRC § 7202

Port Newark-Elizabeth (Port Newark and the Elizabeth-Port Authority Marine Terminal taken together) is the third-busiest container port on the U.S. East Coast and the largest port on the Atlantic Coast by combined container volume. The ecosystem of dockworkers, customs brokers, freight forwarders, and intermodal-trucking operators produces a layer of federal payroll-tax exposure under IRC § 7202 (willful failure to collect and pay over) and the parallel Trust Fund Recovery Penalty under IRC § 6672, plus FBAR exposure on foreign-bank accounts used for international freight settlement and customs deposits.

Portuguese-American Ironbound FBAR and Streamlined Filing

The Ironbound — the neighborhood east of Newark Penn Station between the rail lines and the Passaic River, also called Down Neck — carries the largest per-capita Portuguese-American population in the United States, rivaled only by Providence, Rhode Island. The overlapping Brazilian-American population on Ferry Street and Wilson Avenue adds a second wave. FinCEN Form 114 (FBAR) obligations on Portuguese and Brazilian bank accounts aggregating over $10,000 trigger our highest-volume Ironbound engagement: prior-year cleanup through the IRS Streamlined Filing Compliance Procedures (Streamlined Domestic Offshore for U.S. residents with non-willful prior non-disclosure), Form 8938 IRC § 6038D reporting once the higher thresholds are met, and treaty-tiebreaker analyses for taxpayers who shifted from Portuguese or Brazilian residency to U.S. residency mid-career.

NJ resident + NY nonresident multi-state wage allocation

A Newark resident commuting via NJ Transit or PATH (from Newark Penn Station, twelve miles east to Lower Manhattan, twenty minutes) to a Manhattan office is taxed by New York as a nonresident on New York-source wages under N.Y. Tax Law § 631 and by New Jersey as a resident on worldwide income under N.J.S.A. 54A:5-1. New Jersey grants a credit for taxes paid to New York under N.J.S.A. 54A:4-1, but the credit is capped at the New Jersey tax that would have applied to the same income. Wage-allocation audits on the NY-source portion are routine.

New York convenience of the employer rule

N.Y. Comp. Codes R. & Regs. tit. 20, § 132.18(a) treats days worked from home in New Jersey as New York-source days for nonresident-PIT purposes when the home office is for the employee's convenience rather than the employer's necessity — a rule upheld in Zelinsky v. Tax Appeals Tribunal, 1 N.Y.3d 85 (2003) and applied aggressively after 2020. For Newark residents in hybrid arrangements with Manhattan employers, documenting employer-necessity is the principal defense.

Audible (Amazon subsidiary) tech RSU and ISO

Audible, the audiobook subsidiary of Amazon, runs its headquarters at 1 Washington Street in downtown Newark and employs an engineering, editorial, and content-production workforce that receives Amazon RSUs (AMZN ticker, vesting on the Amazon four-year cliff schedule). Amazon-style RSU vests at the 22% federal supplemental rate produce the same underwithholding gap as the Prudential and Wall Street West fact patterns. ISO planning for early Audible-Amazon employees and disqualifying-disposition AMT under IRC § 55 are routine engagements.

Rutgers, NJIT, and Newark academic 1099 / NIL / postdoc

Rutgers University-Newark, Rutgers School of Law-Newark, Rutgers Business School-Newark, Rutgers New Jersey Medical School, Rutgers School of Dental Medicine, the New Jersey Institute of Technology, Essex County College, and Bloomfield College together produce a substantial 1099 adjunct-faculty, postdoctoral fellowship, and consulting-honoraria workforce. IRC § 117(c) treats scholarships and fellowships paid in consideration for services as wages, not tax-free scholarship income; IRC § 107 parsonage exclusion applies to clergy at the Newark Archdiocese (Cathedral Basilica of the Sacred Heart) and the multi-denominational Newark religious community. NCAA Name, Image, and Likeness (NIL) payments to Rutgers-Newark athletes are taxable self-employment income under IRC § 61.

Newark-area 1099 physician income

Newark Beth Israel Medical Center (RWJBarnabas Health, 201 Lyons Avenue), University Hospital (operated by Rutgers, 150 Bergen Street), Saint Michael's Medical Center (111 Central Avenue), and the network of attending physicians and surgical groups produce a steady book of 1099 medical income. S-corporation reasonable-compensation defenses, Section 199A QBI computations, retirement-plan compliance, and Trust Fund Recovery Penalty exposure on small-practice payroll are the dominant matters.

New Jersey inheritance tax (Class A / C / D)

New Jersey repealed its estate tax effective January 1, 2018, but retained the inheritance tax under N.J.S.A. 54:34-1 et seq. — making New Jersey, alongside Maryland, one of only two states that retains a state-level death-transfer tax. Rates are graduated by the relationship of the beneficiary to the decedent: Class A (spouse, parent, child, grandchild, other lineal descendants) is fully exempt; Class C (siblings, sons-in-law, daughters-in-law) pays 11% on amounts to $1.075 million and 13% to 14% above; Class D (everyone else — nieces, nephews, cousins, friends, business partners) pays 15% to 16%. Form IT-R filings can stack with federal Form 706 estate tax when the gross estate exceeds the federal exemption.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Newark restaurant (the Ironbound Portuguese and Brazilian dining corridor on Ferry Street and Wilson Avenue), retail, hospitality, customs-broker, intermodal-trucking, and small-construction owners are the most common targets. The IRS uses Form 4180 interviews to identify responsible persons; New Jersey applies a parallel responsible-person rule under N.J.S.A. 54:50-8 to unpaid state withholding and sales tax.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. With Newark Liberty International Airport in the city itself — the largest international gateway in New Jersey — the practical consequence hits Newark's airline-crew workforce, the Portuguese-American and Brazilian-American Ironbound population that travels home regularly, the H-1B and L-1 employees of Prudential and Audible, and the Rutgers Medical School international research faculty. We file the IRC § 7345(e) action to reverse the certification.

Nine common causes of tax debt for Newark taxpayers

Patterns we see repeatedly in Newark engagements. None of them are unusual — all of them are resolvable.

1. Airline-crew multi-state allocation failure

A United pilot or flight attendant based at EWR who lives across state lines — in Pennsylvania, New York, or even Maryland with a base-of-operations swap — gets a withholding mix that fails to track 49 U.S.C. § 40116. The result is a federal refund picture that masks a state assessment a year later. Mid-career base changes are the most common trigger.

2. Underwithheld RSU and ISO at Prudential and Audible

A Prudential vice president or Audible engineer at the 35% or 37% federal marginal bracket sees only 22% supplemental withholding on RSU vests. The shortfall, plus 10.75% New Jersey at the top bracket, produces a five- or six-figure April balance due before any ISO disqualifying-disposition AMT under IRC § 55 is added on top.

3. NY-NJ residency-audit miscalculation

A Newark resident commuting via NJ Transit or PATH from Newark Penn Station to a Manhattan office under-allocates New York-source wage days, or fails to claim the full credit for taxes paid to New York under N.J.S.A. 54A:4-1, and ends up owing both states for the same dollars. The convenience-of-the-employer rule on hybrid-remote arrangements multiplies the exposure.

4. Ironbound restaurant payroll-tax shortfall

When an Ironbound Portuguese or Brazilian restaurant on Ferry Street, Wilson Avenue, or Lafayette Street closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Customs-broker and freight-forwarder businesses tied to Port Newark-Elizabeth show the same pattern.

5. FBAR non-disclosure on Portuguese, Brazilian, Dominican, or Caribbean accounts

A long-tenured Ironbound family with accounts at Banco Espirito Santo, Caixa Geral de Depositos, Banco do Brasil, Bradesco, Banco Popular Dominicano, or another home-country bank routinely crosses the $10,000 FBAR threshold without filing FinCEN Form 114. Streamlined Filing Compliance Procedures clean up the prior years without criminal exposure when the non-disclosure was non-willful.

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. Newark's tech and engineering workforce at Audible and NJIT picked up substantial crypto exposure through 2021-2024.

7. Self-employment underpayment

Newark Beth Israel, University Hospital, and Saint Michael's attending physicians with private 1099 practices, Rutgers and NJIT adjunct faculty, Newark Liberty Airport ride-share drivers, and Ironbound trades 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.

8. 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 Jersey mirrors the federal three-year refund bar under N.J.S.A. 54A:9-8.

9. Real-estate sale without estimated tax

A Forest Hill, Ironbound, or Branch Brook Park-area sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. New Jersey's separate Realty Transfer Fee under N.J.S.A. 46:15-7 (including the "mansion tax" portion at 1% on residential sales over $1 million) is collected at closing and is not a federal deduction.

Eight tax liabilities that pull in Newark taxpayers

Federal authority alongside the New Jersey 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 New Jersey mirror is N.J.S.A. 54:49-4, imposing a 5% per month late-filing penalty on unpaid New Jersey tax, capped at 25%.

Failure to file New Jersey state return

N.J.S.A. 54:49-4 imposes a 5% per month penalty on the unpaid New Jersey tax for failure to file, capped at 25%, with interest under N.J.S.A. 54:48-2 at the prime rate plus three percentage points. The Division of Taxation may issue a Notice of Deficiency under N.J.S.A. 54:49-6, triggering protest rights and ultimately the 90-day New Jersey Tax Court appeal window under N.J.S.A. 54:51A-14.

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 Jersey sales-tax delinquency

N.J.S.A. 54:32B-3 sets the 6.625% state sales tax. The Urban Enterprise Zone reduced rate (3.3125%) applies inside designated Newark UEZ-qualified businesses. N.J.S.A. 54:50-8 imposes personal liability on responsible persons for unpaid trust-fund sales tax.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. New Jersey applies a parallel responsible-person rule under N.J.S.A. 54:50-8 to unpaid state withholding and sales tax.

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.

New Jersey inheritance tax

N.J.S.A. 54:34-1 et seq. imposes a graduated inheritance tax by beneficiary class on transfers from a New Jersey decedent: Class A (spouse, lineal ascendant or descendant) is exempt; Class C (siblings and spouses-of-children) pays 11% to 13% to 14%; Class D (everyone else) pays 15% to 16%. New Jersey repealed its estate tax effective January 1, 2018 (N.J.S.A. 54:38-1 amendment), so the inheritance tax is now the sole state-level death-transfer levy — a structure shared (in some form) only with Maryland. The federal estate tax under Form 706 is a separate layer on top.

Customs-broker IRC § 7202 trust-fund liability

IRC § 7202 imposes a felony-level criminal liability on any person required to collect and pay over tax who willfully fails to do so. For customs brokers and freight forwarders tied to Port Newark-Elizabeth, the responsible-person analysis runs alongside the civil Trust Fund Recovery Penalty under IRC § 6672 and may extend to international-payment FBAR and Form 8938 reporting where settlement accounts are held offshore.

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 Essex County Register of Deeds and Mortgages.

Sample tax-resolution outcomes

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

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

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

Why Victory Tax Lawyers for a Newark federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not New Jersey-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 the Newark location at 970 Broad Street (the Martin Luther King Jr. Federal Building) and the Foley Square location in Manhattan at 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 Newark clients never need a separately admitted New Jersey attorney because the case is, at its core, federal.

For administrative work before the New Jersey Division of Taxation — protests, audit responses, Closing Agreement Applications under N.J.S.A. 54:53-1, and installment-payment requests — we file Form M-5008-R Appointment of Taxpayer Representative and handle the matter remotely. When a case must move to the New Jersey Tax Court (the state's specialized tax tribunal seated at the Richard J. Hughes Justice Complex, 25 Market Street, 7th Floor, Trenton NJ 08611, about 55 miles southwest of Newark) or appeal further to the Superior Court Appellate Division, we coordinate with locally admitted New Jersey counsel under a co-counsel arrangement. The federal portion of the engagement — which is usually the bigger exposure given New Jersey's 10.75% top personal income tax bracket and the federal airline-crew, Prudential RSU, customs-broker, and FBAR layer on 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 $100M+ in cumulative tax relief secured across 2,000+ resolved matters. No marketing claim of being a New Jersey-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Newark 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, and we never have to drive across the country to your Forest Hill, Ironbound, or Weequahic home.

Our seven-step process for Newark 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 M-5008-R

We file the federal Power of Attorney with the IRS and Form M-5008-R with the New Jersey Division of Taxation, 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 a New Jersey Tax Court complaint through local counsel — and handle every IRS and Division of Taxation 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 New Jersey's assessment statute

The IRS has ten years from the date of assessment to collect a federal tax under IRC § 6502. After the Collection Statute Expiration Date, the debt is extinguished by operation of law. The clock pauses ("tolls") when an Offer in Compromise is pending, when a Collection Due Process petition is filed, during bankruptcy, when an installment agreement is requested, and when the taxpayer is outside the United States for six months or more — a tolling event particularly relevant to Newark's airline crew and Ironbound Portuguese-Brazilian residents who travel internationally.

New Jersey runs a parallel state collection rule. N.J.S.A. 54A:9-4 gives the Division of Taxation three years from the return due date to assess additional Gross Income Tax (and most other taxes), extended to six years for omitted income exceeding 25% of gross income reported, with no limit for fraud or unfiled returns. Once a Certificate of Debt is docketed with the Superior Court under N.J.S.A. 54:49-12, it functions as a judgment lien on real property for 20 years and may be renewed. Many Newark taxpayers carry a federal CSED that will run out before the New Jersey state collection rights expire, or vice versa. Pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.

Newark tax authorities and venues

A working knowledge of the tribunals, agencies, and field offices serving Newark is what separates an answered Notice from a wage levy. Below is the working list our firm uses on every Essex County matter.

Internal Revenue Service — Newark TAC

The federal tax authority, at irs.gov. The Newark Taxpayer Assistance Center operates at 970 Broad Street, 14th Floor, Newark NJ 07102, inside the Martin Luther King Jr. Federal Building. This is the primary New Jersey TAC and serves Essex, Union, Morris, Hudson, Bergen, and Passaic Counties. Appointments required.

U.S. Tax Court — Newark and New York trial sessions

The U.S. Tax Court holds regular trial sessions at the Newark location, 970 Broad Street, 14th Floor, Newark NJ 07102 (the Martin Luther King Jr. Federal Building, in the city itself) and at the Foley Square location in Manhattan, 290 Broadway, New York NY 10007 (twelve miles east). A Newark taxpayer may request either 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.

New Jersey Division of Taxation

The state tax authority, at nj.gov/treasury/taxation. Headquartered at 3 John Fitch Way, Trenton NJ 08611, with a Newark regional service office at 210 Park Avenue, Newark NJ. Administers the 1.4% to 10.75% graduated Gross Income Tax under N.J.S.A. 54A:2-1, the 11.5% Corporation Business Tax under N.J.S.A. 54:10A-5, the 6.625% state sales tax under N.J.S.A. 54:32B-3, withholding tax, the Business Alternative Income Tax (BAIT) under N.J.S.A. 54A:12-1 et seq., the New Jersey inheritance tax under N.J.S.A. 54:34-1 et seq., and the New Jersey Closing Agreement program under N.J.S.A. 54:53-1.

New Jersey Tax Court

The state's specialized tax tribunal, established 1979 and seated at the Richard J. Hughes Justice Complex, 25 Market Street, 7th Floor, Trenton NJ 08611, about 55 miles southwest of Newark. Hears disputes between taxpayers and the Director of the Division of Taxation, the State Treasurer, and municipal tax assessors. 90-day complaint deadline from a Final Determination of the Director under N.J.S.A. 54:51A-14. Decisions are appealable to the Superior Court of New Jersey, Appellate Division. Victory Tax Lawyers refers New Jersey Tax Court litigation to locally admitted New Jersey counsel; we handle the federal portion and the Division of Taxation administrative work directly.

City of Newark Department of Finance

The municipal finance authority for Newark, with offices at 920 Broad Street, Room B-26, Newark NJ 07102 (City Hall). Administers Newark property-tax billing and collection, business-license fees, and municipal payroll-tax matters. The Essex County Board of Taxation at 50 South Clinton Street, 5th Floor, East Orange NJ 07018 hears Newark property-tax assessment appeals under N.J.S.A. 54:3-21.

Essex County Treasurer and Register

The county finance authority for Essex County, with the County Treasurer at the Hall of Records, 465 Dr. Martin Luther King Jr. Boulevard, Room 218, Newark NJ 07102. The Essex County Register of Deeds and Mortgages records Notices of Federal Tax Lien and New Jersey Certificates of Debt against Essex County real property — NFTLs encumbering Ironbound, Forest Hill, Weequahic, Vailsburg, North Ward, South Ward, East Ward, West Ward, Central Ward, and Down Neck property are recorded with the Essex County Register.

U.S. District Court — District of New Jersey, Newark Division

Newark is the primary federal courthouse for the District of New Jersey. Refund suits filed after payment of tax and exhaustion of administrative remedies under IRC § 7422 may be brought at the Frank R. Lautenberg Post Office and U.S. Courthouse, 50 Walnut Street, Newark NJ 07102, or alternatively in the U.S. Court of Federal Claims in Washington, D.C. Criminal tax cases under IRC § 7201, § 7202, and § 7206 prosecuted in the District of New Jersey are tried in this courthouse.

IRS Independent Office of Appeals

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

Taxpayer Advocate Service — New Jersey

An independent organization within the IRS that helps when normal channels stall. The New Jersey Local Taxpayer Advocate office serves taxpayers across the state. Page: taxpayeradvocate.irs.gov.

New York State Department of Taxation and Finance

For Newark residents working in Manhattan, New York becomes a second state tax authority. The NY Department of Taxation and Finance administers the nonresident PIT under N.Y. Tax Law § 631 and applies the convenience-of-the-employer rule under N.Y. Comp. Codes R. & Regs. tit. 20, § 132.18(a). Audits and assessments are reviewable by the New York Division of Tax Appeals and ultimately the New York Tax Appeals Tribunal. Page: tax.ny.gov.

Speak with a tax attorney about your Newark matter

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Call (800) 883-8301 Free Consultation

Frequently asked questions — Newark tax

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

The U.S. Tax Court holds regular trial sessions at 970 Broad Street, 14th Floor, Newark NJ 07102 — inside the Martin Luther King Jr. Federal Building in downtown Newark itself. The Foley Square trial location in Manhattan at 290 Broadway, twelve miles east, is the alternative when scheduling or strategy favors it. 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.

I'm a United Airlines pilot or flight attendant based at Newark Liberty (EWR) — how am I taxed across states?

49 U.S.C. § 40116(f) is a federal preemption that overrides ordinary multi-state apportionment for airline crew. Compensation for service in flight is sourced to (1) your state of residence and (2) any state where you earn more than 50% of your compensation. If you live in New Jersey and base at EWR, all of your flight-pay is New Jersey-source even when your trips touch California, Florida, Hawaii, or international destinations. If you live in Pennsylvania, Connecticut, Maryland, or Florida and base at EWR, your flight-pay is sourced to your residency state, not New Jersey — but a residency-audit problem can develop fast if your facts straddle the line. Ground time at the base airport (training, layovers, briefings) is sourced to the state where the airport sits. We resolve the underlying base-of-operations analysis and clean up multi-year W-2 withholding mismatches.

I work at Prudential Financial in Newark and have RSUs — why did I owe so much tax this year?

RSU vest events are taxed as W-2 ordinary income at the supplemental wage withholding rate, currently 22% federal on amounts up to $1 million per year (37% above). If your actual marginal federal rate is 32%, 35%, or 37%, you are underwithheld by 10 to 15 percentage points on every vest. Add 10.75% New Jersey at the top bracket and a single year of vesting can produce a six-figure balance due. Prudential's executive compensation also includes IRC § 409A nonqualified deferred-comp balances; distribution-event errors or election-timing slips inside the § 409A safe harbor produce a 20% additional federal penalty on top of ordinary income tax. The fix is W-4 adjustment, quarterly Form 1040-ES under IRC § 6654, and a clean § 409A election review on every plan year.

I'm Portuguese-American or Brazilian-American in the Ironbound — do I need to file FBAR?

If you are a U.S. person (citizen, green-card holder, or substantial-presence-test resident) and you have signature authority or a financial interest in foreign bank accounts that, in aggregate, exceeded $10,000 at any point during the calendar year — even for one day — you must file FinCEN Form 114 (FBAR) by April 15, with an automatic extension to October 15. This applies to accounts at Caixa Geral de Depositos, Banco BPI, Banco Santander Totta, Millennium BCP, Banco do Brasil, Bradesco, Itau Unibanco, and any other Portuguese or Brazilian bank. If you also exceed the higher IRC § 6038D thresholds ($50,000 single / $100,000 joint at year-end, or $75,000 / $150,000 at any time during the year), you also file Form 8938 with your Form 1040. The IRS Streamlined Filing Compliance Procedures (Streamlined Domestic Offshore for U.S. residents) clean up prior-year non-disclosure with a 5% miscellaneous offshore penalty when the conduct was non-willful — far better than the willful FBAR penalty under 31 U.S.C. § 5321 of up to the greater of $100,000 or 50% of the account balance.

I live in Newark and work in Manhattan — how am I taxed?

You are taxed as a New Jersey resident on worldwide income under N.J.S.A. 54A:5-1 and as a New York nonresident on New York-source wages under N.Y. Tax Law § 631. New Jersey grants a credit for taxes paid to New York under N.J.S.A. 54A:4-1, capped at the New Jersey tax that would have applied to the same income. The credit usually offsets most but not all of the double exposure. The wage allocation between New York-office days and New Jersey-home-office days is the key audit issue, complicated by the New York convenience-of-the-employer rule under N.Y. Comp. Codes R. & Regs. tit. 20, § 132.18(a). New York City personal income tax does not apply to nonresidents (only the New York State portion does), so the NYC 3.876% local rate is not your problem — until and unless you are reclassified as a New York City statutory resident under the 183-day / permanent-place-of-abode test.

What is the New Jersey Tax Court and what is its deadline?

The New Jersey Tax Court is the state's specialized tax tribunal, established 1979 and seated at the Richard J. Hughes Justice Complex, 25 Market Street, 7th Floor, Trenton NJ 08611, about 55 miles southwest of Newark. It hears disputes between taxpayers and the Director of the Division of Taxation, the State Treasurer, and municipal tax assessors. The complaint deadline is 90 days from a Final Determination of the Director under N.J.S.A. 54:51A-14, aligned with the federal Tax Court 90-day deadline. Decisions are appealable to the Superior Court of New Jersey, Appellate Division. Victory Tax Lawyers refers New Jersey Tax Court litigation to locally admitted New Jersey counsel; we handle the federal portion and the Division of Taxation administrative work directly.

My family member died in New Jersey — do I owe estate tax, inheritance tax, or both?

New Jersey repealed its estate tax effective January 1, 2018, so for deaths after that date there is no New Jersey estate tax. The state retained its inheritance tax under N.J.S.A. 54:34-1 et seq., which is graduated by beneficiary class: Class A (spouse, parent, grandparent, child, grandchild, other lineal descendants) is fully exempt; Class C (siblings, sons-in-law, daughters-in-law) pays 11% on the first $1.075 million and 13% to 14% above; Class D (everyone else — nieces, nephews, cousins, friends, charities not separately exempted, business partners) pays 15% to 16%. New Jersey is one of only two states (Maryland is the other) with this kind of relationship-based state-level death-transfer tax. The federal estate tax under Form 706 is a separate layer that applies regardless of beneficiary class.

I run a customs-broker or freight-forwarder business at Port Newark-Elizabeth — what are my federal payroll-tax exposures?

Two parallel federal tracks apply. IRC § 6672 imposes 100% civil personal liability on responsible persons for unpaid trust-fund employment-tax withholding. IRC § 7202 imposes a felony criminal liability on the same conduct when it is willful — the criminal version of the Trust Fund Recovery Penalty. Customs brokers, freight forwarders, and intermodal-trucking operators serving the Port Newark-Elizabeth container terminals routinely run thin payroll margins; any quarter where the Form 941 trust fund (federal income-tax withholding, employee Social Security and Medicare withholding) is not paid over to the IRS triggers both. If the business also holds international-settlement accounts at foreign banks, the FBAR and Form 8938 reporting overlays add to the exposure. We assess responsible-person scope, defend Form 4180 interviews, and structure parallel federal and New Jersey trust-fund resolutions.

Can I be audited by both the IRS and the New Jersey Division of Taxation for the same year?

Yes. The IRS and the New Jersey Division of Taxation operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to New Jersey under the state's federal-change reporting rule at N.J.S.A. 54A:8-7, and vice versa. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the New Jersey return — particularly important given New Jersey's 10.75% top marginal rate, which produces a sizable state liability on any upward federal adjustment.

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

New Jersey does not use the term "Offer in Compromise" but operates a functionally similar program under N.J.S.A. 54:53-1 called the Closing Agreement program, which permits the Division of Taxation to settle a disputed tax for less than the full amount where doubt as to collectibility or doubt as to liability exists. The Division publishes a Closing Agreement Application for individual and business tax liabilities; all New Jersey returns must be filed before consideration, and a financial-disclosure package is required. We typically run a state Closing Agreement in parallel with a federal Offer in Compromise where both debts are real.

I'm a Rutgers-Newark or NJIT faculty member or postdoc — what are my federal tax issues?

Adjunct faculty paid on 1099 file Schedule C self-employment income subject to 15.3% SE tax plus federal and New Jersey income tax. Postdoctoral fellowships at Rutgers New Jersey Medical School, NJIT engineering labs, and Rutgers Newark research centers are treated under IRC § 117(c) — the scholarship-and-fellowship exclusion does not apply to amounts paid in consideration for services, so most postdoc pay is fully taxable wage income. Clergy serving Newark's many religious institutions use the IRC § 107 parsonage exclusion on housing allowances designated in advance. Rutgers-Newark NCAA student-athletes who receive Name, Image, and Likeness (NIL) compensation report it as taxable income under IRC § 61 and self-employment tax under IRC § 1402. International faculty under H-1B, J-1, or O-1 visas have substantial-presence-test residency questions under IRC § 7701(b) and treaty-tiebreaker options on a year of transition.

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

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 the Newark location at 970 Broad Street and the Foley Square location in Manhattan. For New Jersey Division of Taxation administrative work, we file Form M-5008-R Appointment of Taxpayer Representative and handle the matter remotely. For formal litigation in the New Jersey Tax Court or a Superior Court Appellate Division proceeding, we co-counsel with locally admitted New Jersey 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 Jersey follows a parallel filing-compliance posture; the Division may assess based on the federal-change reporting rule or estimate tax under N.J.S.A. 54:49-6 when a taxpayer fails to file. For dual-residency Newark / New York filers, both states' returns must be brought current together — a federal Streamlined Filing alone leaves the state exposure live.

Can the IRS levy my Newark 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 Chase, Bank of America, Citibank, TD Bank, Wells Fargo, Valley National, Provident Bank, Investors Bank (now part of Citizens), or any New Jersey-chartered institution, and serve wage levies on Newark employers including Prudential Financial, PSEG, Audible, the Rutgers and University Hospital systems, Newark Liberty International Airport tenants, and Port Newark-Elizabeth operators. 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 Jersey issues parallel state Certificates of Debt under N.J.S.A. 54:49-12 that function as Superior Court judgment liens.

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 Jersey state Closing Agreement under N.J.S.A. 54:53-1 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. New Jersey state collection follows a similar pattern: a Form M-5008-R routes Division of Taxation contact, and a pending Closing Agreement under N.J.S.A. 54:53-1 pauses state Certificate-of-Debt enforcement.

About the author

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

Page last reviewed: May 25, 2026. Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every New Jersey statute citation references the New Jersey Statutes Annotated (N.J.S.A.). 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 Jersey Division of Taxation, the U.S. Tax Court, the New Jersey 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 New Jersey or the State of New York; where a New Jersey state-court appearance, New Jersey Tax Court litigation, or a New York Division of Tax Appeals proceeding 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. § 7202 — Willful Failure to Collect and Pay Over Tax
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 Services
26 U.S.C. § 409A — Nonqualified Deferred Compensation
26 U.S.C. § 6038D — Foreign Financial Asset Reporting
26 U.S.C. § 7701(b) — Substantial Presence Test
26 U.S.C. § 107 — Clergy Parsonage Allowance
26 U.S.C. § 117 — Scholarship and Fellowship Exclusion
49 U.S.C. § 40116 — Airline Crew Multi-State Wage Sourcing
N.J.S.A. 54A:2-1 — New Jersey Gross Income Tax rates
N.J.S.A. 54A:4-1 — Credit for taxes paid to other jurisdictions
N.J.S.A. 54A:5-1 — New Jersey resident source-of-income rules
N.J.S.A. 54A:12-1 — Business Alternative Income Tax (BAIT)
N.J.S.A. 54:10A-5 — Corporation Business Tax rate
N.J.S.A. 54:32B-3 — New Jersey sales and use tax
N.J.S.A. 54:34-1 et seq. — New Jersey inheritance tax (Class A / C / D)
N.J.S.A. 54:49-4 — New Jersey failure-to-file penalty
N.J.S.A. 54:49-6 — Notice of Deficiency and assessment authority
N.J.S.A. 54:49-12 — Certificate of Debt as Superior Court judgment
N.J.S.A. 54:50-8 — Responsible-person liability for withheld and sales tax
N.J.S.A. 54:51A-14 — 90-day New Jersey Tax Court complaint window
N.J.S.A. 54:53-1 — New Jersey Closing Agreement program
N.Y. Tax Law § 631 — New York nonresident PIT source rules
N.Y. Comp. Codes R. & Regs. tit. 20, § 132.18(a) — New York convenience-of-the-employer rule