Tax Attorney in Ohio
Federal IRS representation for Ohio taxpayers — audits, back taxes, liens, levies, Offer in Compromise filings, and U.S. Tax Court petitions. Ohio is one of the few states outside the Northeast corridor that layers a state income tax, a gross-receipts Commercial Activity Tax, and municipal income taxes administered through RITA and the Central Collection Agency. Our team handles the federal side and coordinates with state agencies where the matters overlap.
By Parham Khorsandi, Esq. — California Bar #266658. Admitted to practice before the United States Tax Court. Last Reviewed: .
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If you owe back taxes in Ohio, here is what shifted in 2026
The IRS resumed full passport-revocation referrals under IRC §7345 for taxpayers with seriously delinquent federal tax debts exceeding the inflation-adjusted threshold (currently $62,000 for 2026). Ohio residents who travel for work — manufacturing executives at Honda and Intel facilities, cross-border professionals in Toledo and Cleveland, and academic faculty in Columbus and Cincinnati — face real revocation exposure. Ohio also continued phasing down its personal income tax: the top bracket has moved from 3.99% to 3.5% under Ohio Revised Code Chapter 5747, and the Commercial Activity Tax exclusion amount rose to $6 million in 2025, removing many small Ohio businesses from CAT liability while leaving the federal IRS exposure unchanged. Acting before a federal levy hits is materially easier than reversing it after.
$100M+
Total tax relief secured
2,000+
Tax cases resolved
5.0
Average rating · 72 reviews
All 50
States via Form 2848 PoA
Past results do not guarantee future outcomes. Each tax case is unique and turns on individual facts and IRS discretion.
What this page covers and why state-specific representation matters in Ohio
Victory Tax Lawyers, LLP is a California-licensed tax-law firm whose primary practice is federal IRS resolution. We represent Ohio individuals and businesses before the Internal Revenue Service, the U.S. Tax Court, and the IRS Independent Office of Appeals through a Form 2848 Power of Attorney, which is recognized in every IRS district nationwide. Federal tax practice is not constrained by state-bar admission; under 31 CFR §10.3 (Circular 230), attorneys, CPAs, and enrolled agents may represent taxpayers before the IRS regardless of the taxpayer's state of residence.
Ohio is one of the more tax-layered states in the country. Individuals owe federal income tax to the IRS, state income tax to the Ohio Department of Taxation under Ohio Revised Code Chapter 5747, and, for most Ohioans who live or work in Cleveland, Cincinnati, Columbus, Toledo, Akron, Dayton, or any of the roughly 600 Ohio municipalities that levy a local tax, a municipal income tax administered either through the Regional Income Tax Agency (RITA) or the Central Collection Agency (CCA). Businesses face the Ohio Commercial Activity Tax under Ohio Revised Code Chapter 5751 — a gross-receipts tax that replaced the legacy corporate franchise tax in 2005 — and state sales-and-use tax. When those state and municipal matters intersect with a federal case (a closed Cleveland restaurant with unpaid federal payroll trust funds and unpaid Ohio sales tax, for example), we coordinate the federal posture while working alongside Ohio counsel for state-tribunal matters where required.
If your problem is federal, you do not need an attorney admitted in Ohio. You need an attorney admitted somewhere with active U.S. Tax Court bar membership and federal-practitioner credentials under Circular 230. That is what this firm provides.
Your tax rights as an Ohio taxpayer
Federal taxpayer rights are codified across the Internal Revenue Code and summarized in IRS Publication 1, the Taxpayer Bill of Rights. They apply identically to a resident of Chillicothe, Lorain, or Mansfield. The major rights you can invoke in a tax-resolution matter:
Right to representation
Under IRC §7521(b)(2), an IRS examiner or collection officer must suspend an interview if you state you wish to consult with an authorized representative. A signed Form 2848 puts your tax attorney between you and the IRS for the remainder of the matter.
Right to Collection Due Process
After a Notice of Federal Tax Lien (IRC §6320) or a Final Notice of Intent to Levy (IRC §6330), you have 30 days to request a Collection Due Process hearing on Form 12153. CDP requests pause collection enforcement and preserve U.S. Tax Court review.
Right to U.S. Tax Court review
A Notice of Deficiency triggers a 90-day petition window under IRC §6213(a). Filing a petition in Tax Court means you can litigate without paying the deficiency first. Miss the 90 days and your only remedy becomes pay-then-sue in District Court or the U.S. Court of Federal Claims.
Right to an Offer in Compromise
Under IRC §7122, the IRS may accept less than the full liability where doubt as to collectibility, doubt as to liability, or effective tax administration justifies settlement. The offer is filed on Form 656 with Form 433-A(OIC) or 433-B(OIC) financial disclosure.
Right to a Collection Statute
IRC §6502 generally gives the IRS 10 years from the date of assessment to collect, after which the debt becomes uncollectible. Several events toll the period: pending OICs, bankruptcy, CDP hearings, and military deployment. Pull your IRS Account Transcripts to verify your Collection Statute Expiration Date.
Ohio-specific: state SOL on assessment
For state matters, Ohio Rev. Code §5747.13 generally limits the Department of Taxation to four years after the return was due or filed (whichever is later) to issue a deficiency assessment, with longer periods for fraud, substantial omission, or unfiled returns. The federal CSED runs separately, and municipal income-tax assessments under Ohio Rev. Code §718 follow their own three-year audit window in most cases.
How Victory Tax Lawyers helps Ohio taxpayers
Offer in Compromise
We prepare and file Form 656 with the supporting financials under IRC §7122. The IRS evaluates Reasonable Collection Potential (RCP) using your monthly income net of allowable expenses plus the realizable value of assets. We pressure-test the math before submission so the offer reaches Appeals if rejected at intake.
Installment Agreement
Streamlined IAs (under $50,000), Non-Streamlined IAs over $50,000 with Form 433-F disclosure, and Partial Pay Installment Agreements under IRC §6159 that run only through the CSED. We pick the structure that fits your facts and your runway.
Lien release and withdrawal
A Notice of Federal Tax Lien under IRC §6321 attaches to your Ohio real and personal property. We pursue release after payment, certificate of discharge for specific property, subordination to allow refinancing, and withdrawal under the Fresh Start lien-withdrawal program for IAs of $25,000 or less.
Levy release
Wage levies (CP90 / LT11 series) and bank levies under IRC §6331 stop when we secure CNC status, an accepted IA, an accepted OIC, or a CDP request. Time matters: bank levies hold for 21 days before remittance under IRC §6332(c).
Audit and exam defense
Correspondence audits, office exams, and field audits. We respond to Information Document Requests, attend the audit in your place under Form 2848, prepare the Form 4549 protest if we disagree with proposed adjustments, and take the case to the IRS Independent Office of Appeals if needed.
Penalty abatement
First-Time Penalty Abatement administrative relief and Reasonable Cause requests under IRC §6651. Common reasonable-cause arguments for Ohio filers include factory-closure layoffs across the Mahoning Valley, serious illness, and reliance on a preparer (subject to Boyle limits).
12 types of Ohio tax issues we handle
Federal IRS practice areas, with Ohio-specific framing where relevant.
Unfiled federal and Ohio returns
Ohio filers who skip a federal 1040 almost always skip the IT-1040 and the municipal return as well. We reconstruct prior years using wage and income transcripts, then file federal first and coordinate state and municipal filings to follow.
IRS audit defense
Correspondence, office, and field audits. We respond, document, and protest examination changes through Appeals or U.S. Tax Court.
Trust Fund Recovery Penalty
Under IRC §6672, the IRS pierces the corporate veil for unpaid payroll trust funds. Ohio LLC owners often discover this after a manufacturing-belt business shutters.
Wage and bank levies
CP90 / LT11 final notices, bank account levies, and accounts-receivable levies for Ohio business owners and W-2 employees alike.
Federal tax liens on Ohio property
NFTLs filed with Ohio county recorders cloud title on homes in Cuyahoga, Franklin, Hamilton, Montgomery, and Summit counties, as well as commercial and farm property statewide.
Passport revocation defense
IRC §7345 certifications to the State Department. We work to decertify before travel for Honda and Intel executives, Cleveland Clinic researchers, and Ohio State faculty with international obligations.
Offer in Compromise filings
Doubt as to Collectibility OICs for Ohio filers with limited equity, often paired with Currently Not Collectible status during processing.
Innocent Spouse Relief
Form 8857 relief under IRC §6015. Ohio is not a community-property state, but joint-and-several liability still creates the same exposure after a divorce filed in any Ohio county.
FBAR and offshore disclosure
FinCEN Form 114 for Ohio residents with foreign accounts — Cleveland Clinic international physicians, Procter & Gamble expatriates, and inherited European accounts in heritage Ohio families.
U.S. Tax Court petitions
Deficiency petitions filed in the Tax Court within 90 days of the Notice of Deficiency, with trial sessions in Cleveland (permanent courthouse at the Celebrezze Federal Building), Cincinnati, and Columbus.
Self-employment back taxes
Ohio has a thick layer of 1099 contractors — construction, healthcare locums, building-trades subcontractors, and ride-share drivers in Columbus and Cleveland. Unpaid SE tax under IRC §1401 grows fast.
Cryptocurrency reporting issues
Columbus, Cleveland, and Cincinnati each have growing crypto-trading populations tied to local tech and finance employers. We address unreported gains, Form 1099-DA exposure, and John Doe summons defense.
Nine common causes of tax debt in Ohio
1. Manufacturing-belt layoffs
Plant closures in Lordstown, Youngstown, Dayton, and Mansfield leave displaced workers with severance, retirement-account withdrawals, and unemployment income that produce surprise federal balances when 10% withholding misses the actual tax bracket.
2. Small-business payroll lapses
An Ohio LLC stops depositing 941 trust funds during a slow quarter. The IRS asserts TFRP against the owner personally under IRC §6672. The state side becomes an Ohio Department of Job and Family Services collection for state unemployment tax.
3. Unfiled municipal returns
An Ohio worker who moves between Cleveland, Lakewood, and Parma stops filing the local return because withholding feels handled. RITA or CCA assesses the missing tax plus penalties. The federal return often goes with it.
4. Sold real estate without 1031
Columbus and Cincinnati both saw aggressive 2021-2023 real-estate appreciation. Investment-property sales without a like-kind exchange under IRC §1031 triggered surprise capital-gains balances on the federal side and on the Ohio IT-1040.
5. Misclassified worker disputes
IRS audit reclassifies 1099 contractors as W-2 employees. The retroactive payroll-tax assessment lands on the Ohio employer, often paired with an Ohio Department of Taxation withholding inquiry.
6. ERC clawback exposure
Employee Retention Credit claims submitted by promoter mills are being clawed back through CP207/CP207L letters. Many Ohio restaurants, dental practices, healthcare providers, and contractors face the audit wave.
7. Crypto trading without records
Columbus and Cleveland crypto holders received 1099-K and 1099-MISC reports from exchanges. The IRS matches them to filed returns and issues CP2000 notices for the gap.
8. Healthcare locum 1099 income
Ohio's deep healthcare market — Cleveland Clinic, Ohio State Wexner Medical Center, ProMedica, Mercy Health — produces a steady stream of locum tenens physicians and CRNAs earning 1099 income across multiple states. Quarterly estimates often slip and a six-figure April balance follows.
9. Inherited foreign accounts
Northeast Ohio's deep ethnic communities — Hungarian, Slovak, Italian, Polish, Ukrainian — produce inherited European bank accounts. FBAR (FinCEN 114) and Form 8938 reporting obligations apply, and willful non-filing carries severe penalties.
Who is on the hook: eight tax-liability scenarios
Joint filers
Joint federal returns create joint-and-several liability under IRC §6013(d)(3). One spouse can be pursued for the entire balance. Innocent Spouse Relief under IRC §6015 is the principal escape valve. Ohio is a common-law (separate property) state, so federal joint liability does not automatically reach the other spouse's premarital property the way it does in community-property states — but joint federal returns waive that distinction at the federal level.
Responsible persons for payroll
Trust Fund Recovery Penalty under IRC §6672 reaches anyone who had check-signing authority and willfully failed to pay over withheld taxes — not just officers.
Ohio CAT-tax responsible persons
The Commercial Activity Tax under Ohio Rev. Code Chapter 5751 is the entity's liability, but officers and statutory agents can be held personally responsible for unpaid CAT under Ohio Rev. Code §5751.09 if the entity dissolves before paying.
Transferee liability
IRC §6901 reaches a transferee of assets where the transfer rendered the transferor insolvent and tax debts remain unpaid. Ohio family-LLC restructurings and farm-succession transfers sometimes trigger this.
Successor business under §6324
Asset purchases where the buyer continues the seller's business operations can carry forward IRC §6324 estate-tax liability and analogous successor exposure for income tax. Ohio sales-tax successor liability under Ohio Rev. Code §5739.14 reaches the buyer of a business if the buyer does not obtain a release from the Department of Taxation.
Nominee and alter-ego
The IRS files a nominee or alter-ego lien when assets titled in another's name actually belong to the taxpayer. Common in Ohio holding-company structures where the operating LLC has the tax debt and the real estate sits in a separate entity.
Ohio sales-and-use tax personal liability
Unpaid Ohio state sales tax under Ohio Rev. Code Chapter 5739 can be assessed personally against any officer, employee, or trustee who had the duty to collect and remit. The state-tax responsible-person standard parallels federal TFRP under IRC §6672.
Estate and decedent returns
A decedent's final 1040 and the estate's 1041 are the executor's responsibility. Personal liability for the executor attaches under 31 USC §3713(b) if distributions are made before federal tax claims are satisfied. Ohio repealed its state estate tax for deaths on or after January 1, 2013, so this is now a purely federal concern for Ohio decedents.
What resolution can look like
Debt reduced
An accepted Offer in Compromise settles the federal liability for less than the full amount. Partial Pay IAs cap the recovery at what you can pay through the CSED. Currently Not Collectible status freezes collection.
Penalties abated
First-Time Penalty Abatement removes failure-to-file and failure-to-pay penalties for a clean compliance year. Reasonable-cause requests address plant-closure layoffs, serious illness, and preparer reliance.
Liens and levies released
An NFTL withdraws once a streamlined IA is in place under Fresh Start. Wage and bank levies release when the underlying account moves to CNC, IA, or OIC processing. Passport certifications are reversed once the debt drops below the §7345 threshold.
Outcomes vary. Past results do not guarantee future outcomes. Each tax case is unique.
Settlement ranges from the firm's case files
The following ranges come from Victory Tax Lawyers cases over the past several years and contribute to the firm's $100M+ aggregate tax-relief figure. Names and identifying facts are removed for confidentiality.
| Matter type | Original liability | Resolution | Approximate result |
|---|---|---|---|
| Installment Agreement | $138,296 | IRC §6159 streamlined IA | $25/month accepted |
| Partial Pay IA | $126,489 | IRC §6159 PPIA through CSED | $50/month accepted |
| Installment Agreement | $128,206 | IRC §6159 streamlined IA | $25/month accepted |
| Partial Pay IA | $116,451 | IRC §6159 PPIA through CSED | $50/month accepted |
| Installment Agreement | $152,296 | IRC §6159 streamlined IA | $25/month accepted |
Past results do not guarantee future outcomes. Each tax case is unique and turns on facts, asset position, monthly disposable income, IRS Allowable Living Expense tables, and the discretion of the assigned Revenue Officer or Settlement Officer. Acceptance rates for Offer in Compromise vary widely — the IRS reported a nationwide acceptance rate of roughly 30 to 40 percent in recent years.
Why a California-licensed firm represents Ohio taxpayers
Federal tax practice is regulated by Treasury under 31 CFR Part 10 (Circular 230). An attorney admitted in any U.S. jurisdiction may represent any taxpayer before the IRS in any state via Form 2848 Power of Attorney. State-bar admission is a state-court question; the IRS is a federal agency, the U.S. Tax Court is a federal court of national jurisdiction, and the IRS Independent Office of Appeals is a federal administrative venue.
Parham Khorsandi is a member of the State Bar of California (license #266658) and is admitted to practice before the United States Tax Court — admission to that court is national, not state-bound. Amir Boroumand (Cal Bar #269570) supplements the firm's federal practice.
For matters that require an attorney admitted in Ohio — for example, an Ohio Board of Tax Appeals contest that advances to Ohio Supreme Court review, or a municipal-income-tax appeal in a Cuyahoga or Franklin County court — we coordinate with Ohio counsel and stay engaged on the federal-tax side. Most VTL Ohio cases are pure federal practice and do not require Ohio-bar representation at all.
The seven steps of a VTL tax-resolution engagement
Free consultation
A 30-minute call with an attorney to outline the facts, the IRS notices received, and the realistic resolution options.
Engagement letter
A written attorney-client agreement defines scope, fee, and authority. Federal common-law attorney-client privilege attaches.
Form 2848 filed
Power of Attorney filed with the IRS Centralized Authorization File so all subsequent IRS notices route to the firm.
CAF investigation
Account Transcripts, Wage and Income Transcripts, and Record of Account pulled across all open tax years. CSED dates verified.
Strategy memo
A written analysis recommending OIC, IA, CNC, audit response, CDP, or Tax Court petition based on the financial profile.
Resolution filed
Forms 656, 433-A, 9423, 12153, or Tax Court Petition prepared and filed. Negotiations with Revenue Officers, Settlement Officers, or Appeals Officers handled directly.
Compliance close-out
Post-resolution monitoring: future quarterly estimates, return filings, and protection against IA default. The case is not done when the offer is accepted; it is done when the new pattern is stable.
Collection statute warning — federal and Ohio
Under IRC §6502(a), the IRS generally has ten years from the date of assessment to collect a tax. After the Collection Statute Expiration Date, the debt becomes uncollectible by operation of law. Several events toll or extend the CSED, including a pending Offer in Compromise (extends by the OIC pendency plus 30 days), bankruptcy filing (extends by the bankruptcy stay plus six months), a Collection Due Process hearing (extends while pending), Innocent Spouse claims, and continuous absence from the United States for six months or more.
On the Ohio state side, Ohio Rev. Code §5747.13 gives the Department of Taxation four years from the date the return was due or filed to issue an income-tax assessment, with longer periods for fraud, substantial omission, and unfiled returns. Ohio sales-and-use tax assessments under Ohio Rev. Code §5739.16 follow the same four-year window. Once assessed and certified to the Attorney General for collection under Ohio Rev. Code §131.02, the state collection tail can run for years.
Before negotiating any resolution, pull your IRS Account Transcripts and verify your CSED dates. Submitting an OIC restarts an already-running clock; sometimes a Partial Pay Installment Agreement that runs out the statute is the better strategy than an offer that extends it.
Ohio venue: where federal and state tax matters are heard
Federal tax matters affecting Ohio taxpayers proceed in federal venues. State tax disputes proceed through the Ohio Department of Taxation appeal process and the Ohio Board of Tax Appeals, with further review available in the Ohio Supreme Court under Ohio Rev. Code §5717.04. Municipal income-tax disputes proceed through RITA or CCA administrative review and into the county Court of Common Pleas.
U.S. Tax Court — Ohio trial sessions
The United States Tax Court holds trial sessions in Cleveland at the Anthony J. Celebrezze Federal Building (1240 East 9th Street, Room 3013, the only permanent courtroom in Ohio), plus Cincinnati and Columbus on a rotating-session basis. An Ohio petitioner designates the preferred place of trial in the petition under Tax Court Rule 140; cases are generally calendared to the nearest session.
IRS Taxpayer Assistance Centers
The IRS operates TACs in Cleveland, Cincinnati, Columbus, Akron, Dayton, Toledo, and Youngstown, with additional satellite locations. Appointments are scheduled through the IRS office locator or 844-545-5640.
Ohio Department of Taxation
The Ohio Department of Taxation administers state personal income tax under Ohio Rev. Code Chapter 5747, the Commercial Activity Tax under Chapter 5751, sales-and-use tax under Chapter 5739, and pass-through entity tax. The Department's main office is in Columbus; field representation is statewide.
Ohio Board of Tax Appeals
The Ohio Board of Tax Appeals is the state-level forum for appeals of Department of Taxation final determinations, county auditor real-property valuations, and municipal board-of-revision decisions. Filings flow through the BTA Resolution Center; appeals from BTA decisions go directly to the Ohio Supreme Court or the appropriate court of appeals.
RITA and CCA municipal collection
The Regional Income Tax Agency (RITA), headquartered in Brecksville, collects municipal income tax for roughly 350 Ohio cities and villages. The Central Collection Agency, based in Cleveland, handles Cleveland, Bratenahl, and other member municipalities. Both maintain their own audit, assessment, and collection authority under Ohio Rev. Code Chapter 718.
Federal District Courts
Ohio has two federal districts: Northern (Cleveland, Akron, Toledo, Youngstown) and Southern (Cincinnati, Columbus, Dayton). Refund suits and criminal-tax cases proceed in the relevant district. Major Ohio cities served include Columbus, Cleveland, Cincinnati, Toledo, Akron, Dayton, Parma, Canton, Youngstown, and Lorain.
Request a free consultation with an Ohio tax attorney
A 30-minute call with an attorney costs nothing. Bring your most recent IRS notice, your last filed return, and any state or municipal correspondence from the Ohio Department of Taxation, RITA, or CCA. We will tell you which resolution options actually fit your facts before you sign anything.
Frequently asked questions for Ohio taxpayers
Reviewed by
Parham Khorsandi, Esq.
Managing Attorney · California Bar #266658 · Admitted to the United States Tax Court
Parham Khorsandi is the managing attorney of Victory Tax Lawyers, LLP. His practice focuses on federal tax controversy, including Offer in Compromise negotiations, Installment Agreements, Trust Fund Recovery Penalty defense, audit representation before the IRS Examination function, and litigation before the U.S. Tax Court. He has represented Ohio individual and business taxpayers in matters across Cleveland, Columbus, Cincinnati, Toledo, Akron, and Dayton federal-tax venues.
Last Reviewed:
Attorney Advertising. Victory Tax Lawyers, LLP is a California-licensed law firm with its principal office at 1100 S. Robertson Boulevard, Los Angeles, CA 90035. Information on this page is general in nature, may not reflect the most recent legal developments, and does not create an attorney-client relationship. This page is not legal advice. Federal tax outcomes depend on individual facts and Internal Revenue Service discretion. Past results do not guarantee future outcomes; each tax matter is unique.
IRS Circular 230 Disclosure. To ensure compliance with requirements imposed by the IRS, any U.S. federal tax advice contained on this page is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing, or recommending to another party any transaction or matter addressed herein.
Ohio-specific note. VTL attorneys are licensed in California. Federal IRS and U.S. Tax Court representation is provided to Ohio residents under Form 2848 Power of Attorney and Tax Court bar admission, which are recognized in all 50 states. State and municipal matters requiring Ohio-bar admission are handled in coordination with Ohio counsel. Consult a licensed attorney about your specific situation before acting on any content on this page.
Related VTL practice areas
Offer in Compromise
IRC §7122 settlement
Installment Agreement
IRC §6159 payment plan
Tax Lien
IRC §6321 release
Tax Levy
IRC §6331 release
Audit Representation
IRS exam defense
Penalty Abatement
First-Time and reasonable cause
Back Taxes
Unfiled returns and balances
See other states
All 50 areas we serve
Cities we serve in Ohio
Victory Tax Lawyers represents Ohio taxpayers before the IRS, U.S. Tax Court, and federal tax authorities. Federal practice is not constrained by state-bar admission — under 31 CFR §10.3 (Circular 230), our attorneys may represent Ohio taxpayers on federal tax matters through a Form 2848 Power of Attorney.