Tax Attorney in Overland Park, Kansas
Federal IRS representation for Overland Park individuals and businesses across Johnson County — audits, back taxes, liens, levies, T-Mobile and former Sprint employee RSU and ISO tax questions, Kansas City metro KS-MO dual-residency disputes, Bay Area and Chicago relocation departing-resident audits, FBAR and Streamlined Filing for the Johnson County Indian-American and Korean-American H-1B and L-1 community, and U.S. Tax Court litigation at the federal trial cities of Kansas City (515 East 9th Street, KCMO) or Wichita (101 N Main Street). We also coordinate Kansas Department of Revenue and Kansas Board of Tax Appeals matters under IRS Form 2848 federal Power of Attorney and Kansas Form K-2848 state Power of Attorney where they sit alongside a federal case. This page covers Overland Park — the largest city in Johnson County and the wealthiest suburb of the Kansas City metro on the Kansas side of the state line.
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If you owe back taxes in Overland Park, here is the 2026 picture
Kansas runs a graduated personal income tax of 3.10% to 5.7% under K.S.A. § 79-32,110, with the top bracket sitting at 5.7% on Kansas taxable income above the upper threshold — real money for T-Mobile and former Sprint employees stacking RSU vesting income, Bay Area and Chicago relocators sitting on departing-state residency exposure, Johnson County physicians at Overland Park Regional Medical Center and Saint Luke's South, and Corporate Woods professional-services partners stacking federal-plus-state liability. Kansas also imposes a graduated 4% to 7% Corporate Income Tax under K.S.A. § 79-32,110, the 6.5% state sales tax under K.S.A. § 79-3603, plus Johnson County's 1.475% local sales tax and the City of Overland Park's 1.125% city sales tax for a combined 9.1% sales-tax rate on most taxable transactions inside Overland Park city limits. The grocery sales tax sits on the HB 2106 (2022) phase-down schedule. Property taxes are issued by the Johnson County Treasurer at 111 South Cherry Street, Suite 1500, Olathe (roughly 5 miles south of Overland Park), with assessments handled by the Johnson County Appraiser at 111 South Cherry Street, Suite 3000, Olathe.
If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, a Kansas Department of Revenue Notice of Assessment, a California Franchise Tax Board departing-resident audit notice (Form 4505 or NPA), an Illinois Department of Revenue residency assessment, or a Johnson County Treasurer billing notice for unpaid property tax, 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 Kansas Form K-2848 with the Kansas Department of Revenue, coordinate parallel filings with the California FTB or Illinois DOR where the departing-state assessment is live, and put administrative brakes on collection while the case is built.
Federal tax representation for Overland Park 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 trial sessions in Kansas City at the Charles Evans Whittaker United States Courthouse, 400 East 9th Street, Kansas City MO (roughly 18 miles northeast of downtown Overland Park) and in Wichita at 101 N Main Street (roughly 200 miles southwest). From our Robertson Boulevard office in Los Angeles, we represent Overland Park residents, T-Mobile US employees at the Overland Park second-headquarters campus, former Sprint employees holding legacy equity, Applebee's corporate staff at Dine Brands, Waddell & Reed legacy professionals (post-Macquarie 2021), Yellow / YRC Worldwide alumni, NetSmart Technologies engineers, Johnson County physicians, Johnson County Community College and KU Edwards Campus faculty, Bay Area and Chicago and NYC relocators, and Johnson County small-business owners 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. The IRS Taxpayer Assistance Center serving Overland Park is the Overland Park TAC at 5799 Broadmoor Street, Overland Park KS 66202 — an unusual convenience for a Kansas City metro suburb. Additional regional coverage runs through the Kansas City Missouri TAC at 30 West Pershing Road, KCMO 64108.
For Kansas state-tax matters — the graduated 3.10% to 5.7% personal income tax under K.S.A. § 79-32,110, the 4% to 7% graduated Corporate Income Tax, the 6.5% state sales tax under K.S.A. § 79-3603, withholding-tax assessments, and contested matters headed to the Kansas Board of Tax Appeals — we file Kansas Form K-2848 Power of Attorney with the Department of Revenue and handle the administrative track directly. The Kansas Department of Revenue is headquartered at the Docking State Office Building, 915 SW Harrison Street, Topeka KS 66612, roughly 75 miles northwest of Overland Park; there is no dedicated Overland Park field office, so KDOR contact routes through the Topeka headquarters with regional Johnson County coverage. For formal proceedings before the Kansas Board of Tax Appeals at the Eisenhower State Office Building, 700 SW Harrison Street, Suite 1022, Topeka, under the 30-day petition window of K.S.A. § 74-2438, we appear administratively under the K-2848 POA where appropriate, and for further appeal to the Kansas Court of Appeals or the Kansas Supreme Court, we refer to locally admitted Kansas counsel under a co-counsel arrangement. The federal layer is where most Overland Park telecom-equity, departing-resident, and international-mobility cases live, and that is where our engagement carries the load.
Overland Park — population roughly 200,000, the largest city in Johnson County, and the wealthiest KS-side suburb of the Kansas City metro — sits at an unusual intersection of telecom, professional-services, healthcare, and post-2020 relocation tax exposure. T-Mobile US maintains its second headquarters in Overland Park (the legacy Sprint campus on the College Boulevard corridor, retained alongside Bellevue, Washington after the 2020 Sprint-T-Mobile merger), driving thousands of telecom RSU, ISO, ESPP, and IRC § 83(b) election questions for vesting employees plus 1099 cell-phone-store franchise and Schedule C dealer income. Applebee's Restaurants (owned by Dine Brands Global) is headquartered here, as are NetSmart Technologies, the Waddell & Reed legacy footprint after the 2021 Macquarie acquisition, Yellow / YRC Worldwide trucking-industry alumni after the 2023 closure, and Humana's regional back-office operations. The Overland Park healthcare cluster — Overland Park Regional Medical Center, Menorah Medical Center, Olathe Medical Center, Saint Luke's South, and the Kansas City Cancer Center — generates a steady stream of 1099 physician income, partnership K-1s, and physician-practice payroll cases. Johnson County Community College (JCCC), the largest community college in Kansas; the KU Edwards Campus (the University of Kansas's Overland Park footprint); Park University Overland Park; and Mid-America Christian University add academic W-2 and §117(c) fellowship work plus IRC § 107 clergy housing-allowance cases for Overland Park-area faith communities. The post-2020 wave of California, Illinois, and New York high-earner relocations to Johnson County — drawn by Blue Valley and Shawnee Mission school-district reputations and a cost-of-living that runs roughly half of San Francisco — produces a heavy book of California FTB departing-resident audits and Illinois DOR residency disputes. Add the KS-MO commuter dynamic (Overland Park residents working in Kansas City Missouri pay both Kansas 5.7% PIT and KCMO's 1% earnings tax with limited credit), the large Indian-American, Korean-American, Chinese-American, and Vietnamese-American H-1B and L-1 population (one of the highest Asian-American per-capita counts of any KS county), and the federal-procedures-are-uniform but the facts are Overland Park-specific.
Your tax rights as an Overland Park taxpayer
Two parallel rights frameworks apply when you owe tax in Overland Park. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from the Kansas Statutes Annotated Chapter 79 (taxation) and Chapter 74 Article 24 (Kansas Board of Tax Appeals). For taxpayers carrying departing-state exposure from California, Illinois, or New York, a third rights track applies under the relevant state's residency-audit statute. Knowing all three is the difference between a clean resolution and a missed 30-day Board of Tax Appeals petition window that ends in a Kansas state tax warrant filed against your Corporate Woods, Indian Creek, or Blue Valley 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. Kansas mirrors this through Form K-2848 Power of Attorney filed with the Kansas Department of Revenue, which routes all KDOR contact through counsel. California FTB residency audits accept FTB Form 3520-PIT for parallel representation.
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. Overland Park petitioners can request a Kansas City trial location (400 East 9th Street, KCMO, roughly 18 miles northeast) or a Wichita trial location (101 N Main Street, roughly 200 miles southwest) — Kansas City is the practical default for Johnson County.
Right to Board of Tax Appeals review
K.S.A. § 74-2438 gives you 30 days from a final Kansas Department of Revenue determination to appeal to the Kansas Board of Tax Appeals (BOTA) — an independent state tribunal at the Eisenhower State Office Building, 700 SW Harrison Street, Suite 1022, Topeka, established under K.S.A. § 74-2433. The 30-day window is materially shorter than the federal 90-day Tax Court deadline. Missing it forfeits administrative review before judicial appeal becomes available.
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 in U.S. Tax Court. Kansas tax warrants follow a parallel administrative track with the Johnson County District Court at 100 North Kansas Avenue, Olathe.
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. Kansas runs a parallel settlement and abatement authority through the Kansas Department of Revenue under K.S.A. § 79-3233 (refund and credit) and the Secretary's discretionary settlement power, requiring full return-filing compliance and a documented financial-disclosure package.
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 — we have used it on telecom RSU disputes and departing-resident assessments where the IRS or a state agency held a weak position too long.
How Victory Tax Lawyers helps Overland Park 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 Overland Park taxpayers, a federal OIC does not resolve Kansas state liability; we run a parallel Kansas Department of Revenue settlement filing under the K.S.A. § 79-3233 framework and the Secretary's discretionary authority. Where a California FTB or Illinois DOR balance is also open from a prior residency period, we coordinate the state-side OIC equivalents (FTB Form DE 999A for CA, Illinois Board of Appeals settlement for IL) on the same timeline.
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 — an underused resolution path for T-Mobile and former Sprint employees carrying RSU-driven federal debt between $75,000 and $400,000, Corporate Woods professional-services partners, Johnson County physicians on K-1 income, and Overland Park small-business owners.
Lien discharge, subordination, and withdrawal
When a Notice of Federal Tax Lien blocks an Overland Park property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Johnson County Register of Deeds at 111 South Cherry Street, Olathe encumber title on Corporate Woods, College Boulevard corridor, Indian Creek, Nall Hills, Brookridge, Leawood-adjacent, and Blue Valley-school-district properties. The IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing, which is often tight for Johnson County executive-relocation transactions.
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. Wage levies on T-Mobile US payroll, Applebee's / Dine Brands corporate payroll, NetSmart Technologies, Overland Park Regional Medical Center, Saint Luke's South, Menorah Medical, and Johnson County government can be released through a documented IA or hardship filing within days. Kansas state tax warrants follow a parallel track and are filed with the Johnson County District Court at 100 North Kansas Avenue, Olathe.
Audit defense and U.S. Tax Court litigation
Correspondence audits, office audits, and field examinations — including sensitive issues like telecom RSU and ISO basis disputes, IRC § 83(b) election validity, ESPP qualifying-versus-disqualifying disposition, California FTB and Illinois DOR departing-resident audits running in parallel with a federal residency issue, IRC § 911 Foreign Earned Income Exclusion for assignment-abroad telecom executives, FBAR (FinCEN Form 114) and IRC § 6038D Form 8938 for the Johnson County Indian-American and Korean-American H-1B and L-1 community, clergy IRC § 107 housing allowance, physician partnership K-1 audits, and cryptocurrency. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window for trial in Kansas City or Wichita.
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. FBAR penalty cases under 31 U.S.C. § 5321 carry their own non-willful (capped at $10,000 per violation, inflation-adjusted) and willful (greater of $100,000 or 50% of account balance) tracks; Streamlined Filing Compliance Procedures can clean up past non-compliance for eligible Johnson County international taxpayers. Kansas penalties under K.S.A. § 79-3228 follow a separate reasonable-cause analysis applied by KDOR.
Twelve types of Overland Park tax matters we handle
Federal cases for Overland Park residents and businesses, framed against the Kansas Department of Revenue overlay and the California / Illinois / Missouri departing-state overlay where they matter.
T-Mobile US and former Sprint RSU and ISO equity cases
T-Mobile US runs its second headquarters in Overland Park (the legacy Sprint campus retained after the 2020 merger), driving thousands of vesting RSU events plus legacy Sprint ISO exercises, ESPP qualifying-disposition questions, and IRC § 83(b) elections on restricted stock. Common audit issues: RSU income reported on Form W-2 box 1 with no taxpayer-tracked supplemental withholding for top-bracket exposure, ISO Alternative Minimum Tax under IRC § 55 on exercise spreads, ESPP qualifying-versus-disqualifying basis disputes, and dual-state allocation when an employee transferred from the Bellevue Washington T-Mobile HQ to the Overland Park campus (or vice versa) mid-year.
California FTB departing-resident audits for Bay Area relocators
Overland Park is one of the top destinations in the central United States for Bay Area HNW relocators leaving California's 13.3% top PIT. The California Franchise Tax Board pursues departing residents under 18 Cal. Code Regs. § 17014 (residency factors) and the closest-connections test of Bragg v. FTB. Common issues: a sub-546-day “safe harbor” argument under R&TC § 17014(d), severance of California domicile, the FTB Form 4505 protest and Notice of Proposed Assessment (NPA) process, and parallel federal-state coordination on the year-of-move return. We work the federal side directly and coordinate the California FTB protest through California Bar admission.
Illinois departing-resident audits for Chicago relocators
Illinois imposes a flat 4.95% individual income tax under 35 ILCS 5/201 and pursues departing residents under 86 Ill. Adm. Code 100.3020. Common issues: severance of Illinois domicile, the Illinois 183-day presence test, allocation of RSU income vesting through a CME Group, McDonald's HQ Chicago, Boeing Arlington, or Caterpillar Peoria former-employer relocation to Overland Park, and the Illinois Independent Tax Tribunal protest window. We handle the federal layer directly and refer Illinois Tribunal litigation to locally admitted counsel.
Kansas-Missouri commuter and KCMO 1% earnings tax
A meaningful share of Overland Park residents work in Kansas City Missouri (roughly 15 miles northeast), creating a unique multi-jurisdictional stack: federal income tax, Kansas 3.10% to 5.7% PIT on residence, Missouri non-resident PIT on MO-source wages (with KS credit under the KS-MO reciprocity provision), and the Kansas City Missouri 1% earnings tax for non-residents who work in KCMO under KCMO Ordinance 68-381. Kansas allows credit for Missouri state PIT paid on MO-source wages under K.S.A. § 79-32,111 but does NOT allow credit for the KCMO local 1% earnings tax — meaning the KCMO 1% is genuine extra liability on top of full Kansas 5.7%. We resolve federal and reconcile the KS-MO state allocation; we coordinate the KCMO earnings-tax refund pathway via KCMO Form RD-109 where the taxpayer worked from home in Overland Park on covered days.
FBAR, Form 8938, and Streamlined Filing for the Johnson County H-1B and L-1 community
Johnson County hosts one of the highest Asian-American per-capita populations of any KS county — including a large Indian-American (Sprint / T-Mobile / NetSmart H-1B and L-1 transfers), Korean-American, Chinese-American, and Vietnamese-American community. FBAR exposure: FinCEN Form 114 on aggregate foreign accounts over $10,000 under 31 U.S.C. § 5314. IRC § 6038D requires Form 8938 reporting on specified foreign financial assets above the threshold. We handle Streamlined Filing Compliance Procedures (Domestic and Foreign) for past non-compliance, ITIN applications on Form W-7 for non-residents without an SSN, IRC § 911 Foreign Earned Income Exclusion for U.S. citizens on assignment, and IRC § 1441 nonresident-alien withholding analysis.
Physician 1099 and partnership K-1 cases
Overland Park Regional Medical Center, Menorah Medical Center, Olathe Medical Center, Saint Luke's South, the Kansas City Cancer Center, and the broader Johnson County physician network produce a steady stream of 1099 hospitalist income, locum-tenens contracts, partnership K-1 cases for physician-owned groups, and IRC § 199A qualified-business-income analysis on physician PSAs (specified service trades or businesses subject to phase-out above the high-income threshold). Common audit issues: SEP-IRA and solo 401(k) contribution substantiation, IRC § 162 unreimbursed-business-expense disallowance, malpractice-premium deduction questions, and home-office deduction for telehealth physicians post-2020.
Notice of Federal Tax Lien on Overland Park real estate
NFTLs filed with the Johnson County Register of Deeds encumber title and trigger CDP rights under IRC § 6320. Kansas may also file a state tax warrant in the Johnson County District Court under K.S.A. § 79-3233f. Corporate Woods condominium sales, College Boulevard corridor commercial-real-estate refinances, Indian Creek, Nall Hills, Brookridge, Leawood-adjacent, and Blue Valley school-district executive-home transactions stall fast when a tax lien hits the title search. Johnson County executive-relocation closings move on tight timelines — lien-clearance work has to start early.
IRS bank or wage levy at Overland Park employers
Bank levies on accounts at Commerce Bank, Bank of America, U.S. Bank, Capitol Federal, Country Club Bank, Brotherhood Bank, and other Johnson County institutions. Wage levies hit Overland Park employers within days of CP90 or LT11 issuance — T-Mobile US payroll, Applebee's / Dine Brands corporate, NetSmart Technologies, Overland Park Regional Medical Center, Saint Luke's South, Menorah Medical, Olathe Medical, Blue Valley USD 229 and Shawnee Mission USD 512 school-district payrolls, Johnson County government, and Johnson County Community College. We move quickly on Form 668-W levies via Collection Due Process or hardship release under IRC § 6343 economic hardship.
Trust Fund Recovery Penalty for Johnson County small business
IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Common targets: Corporate Woods professional-services firms, College Boulevard corridor tech startups, Overland Park-area restaurant and retail tenants, Applebee's franchise operators, construction firms working the Johnson County executive-home market, and Johnson County professional-services partnerships. The IRS uses Form 4180 interviews to identify responsible persons; Kansas applies a parallel responsible-person rule to withheld state PIT under K.S.A. § 79-3234.
Clergy IRC § 107 housing allowance for Overland Park faith communities
IRC § 107 excludes from gross income the fair-rental-value housing allowance paid to a “minister of the gospel” for service in the exercise of ministry, with related substantiation under Treas. Reg. § 1.107-1. Johnson County hosts a large concentration of evangelical, Catholic, Jewish (Menorah Medical Center area), and Korean Christian congregations. Common audit issues: the dual-status (W-2 plus self-employment) clergy classification, SECA tax under IRC § 1402(e), exemption election under IRC § 1402(e)(1), and parsonage-allowance designation timing required before payment. Mid-America Christian University and Park University faculty in religious-studies roles add an academic-clergy overlay.
JCCC and KU Edwards Campus academic and §117 fellowship cases
Johnson County Community College (the largest community college in Kansas, on Quivira Road in Overland Park), KU Edwards Campus (the University of Kansas's Overland Park location at 12600 Quivira), Park University Overland Park, and Mid-America Christian University drive academic W-2 income, IRC § 117(a) qualified scholarship versus IRC § 117(c) service-payment distinctions on graduate-student stipends, IRC § 174 research-credit substantiation, and IRC § 132 fringe-benefit reclassification audits for faculty. Underwithholding shows up after a summer-grant supplement, an outside-consulting 1099 sideline, or a same-year transition from W-2 to 1099.
Cryptocurrency tax assessments
CP2000 notices on unreported digital-asset gains, basis-tracking failures, and DeFi-protocol income. The Overland Park tech footprint (NetSmart Technologies, the Sprint / T-Mobile engineering talent pipeline, the KU Edwards Computer Science program, and JCCC's IT track) plus the post-2020 Bay Area relocation crowd produces a steady stream of cryptocurrency cases. Form 1099-DA reporting (effective 2025) drives the matching cases. We handle basis-reconstruction, mining-and-staking IRC § 61 ordinary-income substantiation, and DeFi-protocol Wallet-to-Wallet basis tracking.
Nine common causes of tax debt for Overland Park taxpayers
Patterns we see repeatedly in Overland Park engagements. None of them are unusual — all of them are resolvable.
1. T-Mobile / former Sprint RSU vesting with no supplemental withholding
An Overland Park-based T-Mobile US engineer or former Sprint manager sees $80,000-$300,000 in RSU vesting income flow through Form W-2 box 1, with payroll withholding capped at the federal supplemental flat 22% rate. The actual marginal rate for a Johnson County household at that income level is 32% or 35% federal plus Kansas 5.7%, leaving a five- or six-figure shortfall the following April. Form 1040-ES estimates fix the going-forward year; we handle the back balance.
2. California or Illinois departing-resident audit fallout
A family relocates from San Francisco, San Jose, Chicago, or NYC to Overland Park for cost-of-living and Blue Valley schools, but maintains a California or Illinois property, dependent registration, voter file, driver's license, or business interest. The departing state issues a residency-audit notice claiming continued domicile, with full PIT plus interest and accuracy-related penalties on the post-move income. Severance documentation has to be built before the move and defended after.
3. Self-employment underpayment
Johnson County physicians on 1099 hospitalist or locum contracts, Corporate Woods consultants, College Boulevard tech startup founders, Overland Park real-estate agents, and Schedule C franchise operators file with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654, and KDOR follows close behind.
4. Business closure or layoff — Yellow / YRC, Sprint legacy, Waddell & Reed wind-down
When an LLC, S-corp, or partnership closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. The 2023 Yellow / YRC Worldwide closure, the post-Macquarie 2021 Waddell & Reed reorganization, and the post-merger Sprint employee transitions left a tail of small-business and severance-related tax cases in Johnson County.
5. 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 across the Blue Valley and Shawnee Mission HNW corridor where one spouse held the financial files and the other signed at the kitchen table.
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. Common for Overland Park tech employees who bought crypto on Sprint or T-Mobile RSU proceeds and for relocators who held positions through 2021-2024.
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. Kansas follows a three-year refund bar under K.S.A. § 79-32,105 for state PIT refund claims. Common pattern: a Bay Area relocator who skipped a California part-year return during the move year and a non-resident return in subsequent years.
8. FBAR non-compliance discovery
An H-1B or L-1 holder, naturalized citizen, or green-card holder with India, Korea, China, or Vietnam accounts crosses the $10,000 aggregate threshold under 31 U.S.C. § 5314 and discovers years of missing FinCEN Form 114 and Form 8938 filings. Streamlined Foreign or Domestic procedures can clean up the past for non-willful taxpayers; the penalty exposure on willful FBAR cases is the greater of $100,000 or 50% of the highest aggregate balance.
9. KS-MO commuter allocation error and missed KCMO earnings-tax refund
An Overland Park resident who works for an employer headquartered in Kansas City Missouri pays the KCMO 1% earnings tax via payroll withholding under KCMO Ordinance 68-381. For days actually worked from home in Overland Park (or anywhere outside KCMO city limits), the resident is entitled to a refund of the 1% under KCMO Form RD-109NR. The refund must be claimed by the deadline. Many post-2020 hybrid-work residents have never filed and have left years of refund money on the table.
Eight tax liabilities that pull in Overland Park taxpayers
Federal authority alongside the Kansas 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 Kansas mirror is K.S.A. § 79-3228 imposing a late-filing penalty on unpaid Kansas tax.
Failure to file Kansas state return
K.S.A. § 79-3228 imposes the late-filing penalty on unpaid Kansas PIT, plus interest. The Department of Revenue may issue a Notice of Assessment under K.S.A. § 79-3226, triggering the 60-day informal-conference window followed by the 30-day Board of Tax Appeals petition under K.S.A. § 74-2438. The graduated 3.10% to 5.7% PIT rate applies.
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.
Kansas sales-tax delinquency — 9.1% Overland Park combined
K.S.A. § 79-3603 sets the 6.5% state sales tax. Johnson County adds 1.475% and the City of Overland Park adds 1.125% for a combined 9.1% sales-tax rate inside Overland Park city limits on most taxable transactions. The grocery sales-tax phase-down under HB 2106 is on a continuing schedule. K.S.A. § 79-3617 establishes personal liability for responsible persons on unpaid trust-fund state sales tax.
Trust Fund Recovery Penalty
IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Kansas applies a parallel responsible-person rule to withheld state PIT under K.S.A. § 79-3234.
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.
Kansas Corporate Income Tax
K.S.A. § 79-32,110 imposes a graduated Kansas Corporate Income Tax from 4% on the first tier through 7% on the upper tier — one of the higher state corporate top rates in the central United States, materially above Missouri's flat 4% (a consideration for Overland Park-based businesses choosing between a Kansas or Missouri entity domicile in the metro). Kansas estate tax has been repealed: there is no Kansas state estate tax. Federal estate tax under IRC § 2001 still applies.
Kansas property tax (Johnson County)
Property tax in Overland Park is assessed by the Johnson County Appraiser at 111 South Cherry Street, Suite 3000, Olathe, and collected by the Johnson County Treasurer at 111 South Cherry Street, Suite 1500, Olathe. Assessment appeals route through the County Board of Equalization with further appeal to the Kansas Board of Tax Appeals under K.S.A. § 74-2433. Johnson County's per-capita assessed value sits at the top of the Kansas county distribution, with corresponding mill-levy exposure for Corporate Woods, College Boulevard corridor, Blue Valley school-district, and Indian Creek residential properties.
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 — including Streamlined Filing certifications on past FBAR non-compliance for non-willful Johnson County international taxpayers.
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 Johnson County Register of Deeds.
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, the Kansas Department of Revenue, the California Franchise Tax Board, the Illinois Department of Revenue, and any applicable adjudicating body.
Why Victory Tax Lawyers for an Overland Park federal-tax case
Victory Tax Lawyers is California-Bar-admitted, not Kansas-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 Kansas City (400 East 9th Street, KCMO) and Wichita (101 N Main Street) for Overland Park taxpayers. IRS administrative practice runs on Form 2848 Power of Attorney, which is accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Overland Park clients — T-Mobile and former Sprint employees, Bay Area and Chicago relocators, Corporate Woods professionals, Johnson County physicians, and small-business owners — never need a separately admitted Kansas attorney because the case is, at its core, federal.
For administrative work before the Kansas Department of Revenue — protests, audit responses, settlement submissions, and installment-agreement requests — we file Kansas Form K-2848 Power of Attorney and handle the matter remotely. When a case must move to the Kansas Board of Tax Appeals (the state's independent administrative tribunal at the Eisenhower State Office Building, 700 SW Harrison Street, Suite 1022, Topeka) under the 30-day window in K.S.A. § 74-2438, we appear administratively under K-2848 where appropriate; for formal litigation appealing a BOTA decision to the Kansas Court of Appeals or the Kansas Supreme Court, we coordinate with locally admitted Kansas counsel under a co-counsel arrangement. Departing-resident audits from California get the direct California Bar admission advantage; Illinois Independent Tax Tribunal proceedings are referred to locally admitted Illinois counsel.
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 Kansas-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Overland Park 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 1,500 miles to Robertson Boulevard, and we coordinate around Johnson County business-hours schedules and KS-MO metro court calendars.
Our seven-step process for Overland Park 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 CAF
We file the federal Power of Attorney with the IRS, Kansas Form K-2848 with KDOR, and (where the case requires it) FTB Form 3520-PIT or the Illinois POA, then 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. State balances are reconciled in parallel.
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 Kansas Board of Tax Appeals petition, an FTB protest letter, or a KCMO RD-109NR refund claim — and handle every agency 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 Kansas collection (plus departing-state)
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.
Kansas runs a parallel state collection rule under K.S.A. § 79-3230: the Department of Revenue must assess Kansas income tax within three years of the return due date (or two years from federal change reporting under K.S.A. § 79-32,206), with longer windows for substantial understatement and no limit on assessment in cases of fraud or non-filing. Once a Kansas tax warrant is filed in the Johnson County District Court under K.S.A. § 79-3233f, collection continues until the debt is paid or extinguished.
For Bay Area or Chicago relocators, the California FTB collection statute under R&TC § 19255 runs 20 years from the latest of assessment, abatement, or the filing of a state tax lien — materially longer than the federal 10-year CSED. The Illinois DOR statute of limitations on collection under 35 ILCS 735/5-22 runs 20 years from a final assessment. Many Overland Park taxpayers carry a departing-state tax exposure that will outlast the federal CSED by a decade. Pull every record and know every date before agreeing to any payment plan or amended return that could restart a clock.
Overland Park tax authorities and venues
A working knowledge of the tribunals, agencies, and field offices that touch Overland Park cases is what separates an answered Notice from a wage levy. Overland Park has a dedicated IRS Taxpayer Assistance Center on Broadmoor Street — unusual for a Kansas City metro suburb — while Kansas Department of Revenue and Kansas Board of Tax Appeals sit 75 miles northwest in Topeka. Below is the working list our firm uses on every Overland Park matter.
Internal Revenue Service — Overland Park TAC
The federal tax authority, at irs.gov. The IRS Taxpayer Assistance Center serving Overland Park is at 5799 Broadmoor Street, Overland Park KS 66202. Additional metro coverage runs through the Kansas City Missouri TAC at 30 West Pershing Road, KCMO 64108. Appointments are required at both locations.
U.S. Tax Court — Kansas City and Wichita trial sessions
The U.S. Tax Court holds trial sessions in Kansas City at the Charles Evans Whittaker United States Courthouse, 400 East 9th Street, Kansas City MO 64106 (roughly 18 miles northeast of downtown Overland Park) and in Wichita at 101 N Main Street, Wichita KS 67202 (roughly 200 miles southwest). Kansas City is the practical default for Overland Park petitioners. Petitions are filed at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).
Kansas Department of Revenue
The state tax authority, at ksrevenue.gov. Headquartered at the Docking State Office Building, 915 SW Harrison Street, Topeka KS 66612. There is no Overland Park KDOR field office — all Overland Park state-tax contact routes through Topeka, roughly 75 miles northwest. Administers the graduated 3.10% to 5.7% personal income tax under K.S.A. § 79-32,110, the 4% to 7% Corporate Income Tax, the 6.5% state sales tax under K.S.A. § 79-3603, withholding tax, and the Secretary's settlement authority.
Kansas Board of Tax Appeals (BOTA)
The state's independent administrative tribunal that hears tax appeals from the Department of Revenue and county property-tax appeals. Established under K.S.A. § 74-2433. Seated at the Eisenhower State Office Building, 700 SW Harrison Street, Suite 1022, Topeka KS 66603. Page: kansas.gov/bota. The 30-day petition deadline under K.S.A. § 74-2438 runs from the Department of Revenue's final determination. BOTA decisions are appealable to the Kansas Court of Appeals.
U.S. District Court — District of Kansas, Kansas City Division
Refund suits filed after payment of tax and exhaustion of administrative remedies under IRC § 7422 may be brought in the U.S. District Court for the District of Kansas, Kansas City KS Division, 500 State Avenue, Kansas City KS 66101, or the U.S. Court of Federal Claims in Washington, D.C. The Kansas City KS Division is the primary federal venue serving Overland Park. The Topeka Division at 444 SE Quincy Street remains available.
Johnson County Treasurer and Appraiser
The Johnson County Treasurer collects real-estate and personal-property taxes at 111 South Cherry Street, Suite 1500, Olathe KS 66061 (roughly 5 miles south of Overland Park). The Johnson County Appraiser at 111 South Cherry Street, Suite 3000, Olathe sets the assessed value. Page: jocogov.org. Property-tax appeals route through the County Board of Equalization with further appeal to the Kansas Board of Tax Appeals. NFTLs affecting Overland Park real estate are recorded with the Johnson County Register of Deeds at the same Cherry Street address.
City of Overland Park Finance Department
Overland Park has no city income tax or earnings tax; the city collects the local 1.125% sales tax through KDOR remittance and administers business-license, public-utility, and occupational-license fees through the City of Overland Park Finance Department at 8500 Santa Fe Drive, Overland Park KS 66212. Page: opkansas.org.
KCMO earnings tax — cross-state commuter exposure
For Overland Park residents working in Kansas City Missouri, KCMO Ordinance 68-381 imposes a 1% earnings tax on wages earned within KCMO city limits, regardless of residency. Kansas does NOT allow a credit against Kansas PIT for the KCMO local earnings tax (the K.S.A. § 79-32,111 reciprocity credit applies only to Missouri state PIT, not to local taxes). Refund claims for days worked outside KCMO city limits are filed on KCMO Form RD-109NR. Page: kcmo.gov.
IRS Independent Office of Appeals
The administrative-appeals body within the IRS that resolves cases without litigation. Overland Park cases run through the Appeals offices serving the central United States. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.
Taxpayer Advocate Service — Kansas
An independent organization within the IRS that helps when normal channels stall. The Kansas Local Taxpayer Advocate office serves Overland Park taxpayers through the Wichita coverage area. Page: taxpayeradvocate.irs.gov.
Speak with a tax attorney about your Overland Park matter
Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, a Kansas Department of Revenue Notice of Assessment, a California FTB Notice of Proposed Assessment, an Illinois DOR residency notice, or a Johnson County Treasurer billing notice is in front of you, the deadline to respond is real and short — call today.
Frequently asked questions — Overland Park tax
Where is the closest U.S. Tax Court trial location to Overland Park?
The U.S. Tax Court holds trial sessions in two cities that serve Overland Park petitioners: Kansas City at the Charles Evans Whittaker United States Courthouse, 400 East 9th Street, Kansas City MO (roughly 18 miles northeast of downtown Overland Park) and Wichita at 101 N Main Street (roughly 200 miles southwest). Kansas City is the practical default. Either is acceptable when filing the 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 — a single day late and the federal assessment becomes final.
I moved from California to Overland Park — can the California FTB still audit me?
Yes. The California Franchise Tax Board pursues departing residents under 18 Cal. Code Regs. § 17014 and the closest-connections test articulated in Bragg v. Franchise Tax Board. The FTB looks at where you spend your time, where your immediate family lives, where you keep your dentist and doctor, your driver's license, your voter registration, your safe-deposit box, and where your business interests sit. A clean Overland Park move — new driver's license, voter registration, doctor and dentist transferred, kids enrolled in Blue Valley USD 229 or Shawnee Mission USD 512, full physical relocation, California real estate sold or rented at fair market rent — defeats most audits. Hold a vacation home in Newport Beach or a partnership interest in San Francisco and the audit becomes uphill. Because our managing attorney is California-Bar-admitted, we handle the FTB protest directly via FTB Form 3520-PIT power of attorney and the Notice of Proposed Assessment process.
I moved from Chicago to Overland Park — how does Illinois pursue me?
Illinois imposes a flat 4.95% individual income tax under 35 ILCS 5/201 and pursues departing residents under 86 Ill. Adm. Code 100.3020, applying a domicile test plus a 183-day physical-presence test. Common audit triggers: a retained Chicago condo, Illinois driver's license, Illinois voter registration, or business interest still housed in an Illinois LLC. The Illinois DOR issues a Notice of Deficiency, and the protest window runs through the Illinois Independent Tax Tribunal. We handle the federal layer and the documentation work directly; we refer Illinois Tribunal litigation to locally admitted Illinois counsel under a co-counsel arrangement.
I work in Kansas City Missouri but live in Overland Park — do I pay both states?
Yes, with a credit on one side and a unique gap on the other. Kansas residents working in Missouri pay Missouri non-resident PIT on MO-source wages; Kansas allows a credit under K.S.A. § 79-32,111 for the Missouri state PIT paid, so the wages end up taxed once at the higher of the two rates plus the Kansas 5.7% top bracket. Separately, Kansas City Missouri imposes a 1% earnings tax on wages earned within KCMO city limits under KCMO Ordinance 68-381 — and Kansas does NOT allow a credit for that local 1%. The KCMO 1% is genuine added liability on top of full Kansas PIT for an Overland Park resident working in KCMO. For days actually worked from home in Overland Park (or elsewhere outside KCMO city limits), the resident can claim a KCMO refund on Form RD-109NR. Many post-2020 hybrid-work Overland Park residents have years of unclaimed KCMO refunds available.
I am a T-Mobile (or former Sprint) employee with RSU income — why did I owe so much tax?
Restricted Stock Unit income is W-2 income at the fair market value of the shares on the vesting date under IRC § 83(a). T-Mobile payroll withholds federal tax at the supplemental flat 22% rate (or 37% on the portion above $1 million per year). For an Overland Park engineer or manager whose total compensation lands in the 32% or 35% federal bracket plus Kansas 5.7% PIT, the 22% supplemental withholding falls short by 15 to 18 percentage points. On $200,000 of RSU income, that is a $30,000-$36,000 shortfall the following April. The fix is a Form W-4 adjustment (extra withholding) or quarterly Form 1040-ES payments under IRC § 6654. ISO exercises add Alternative Minimum Tax under IRC § 55 on the exercise spread; ESPP qualifying versus disqualifying disposition adds another layer. We resolve the back balance and set the going-forward structure.
Can a California-Bar-admitted attorney represent me in Overland Park?
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 Kansas City and Wichita for Overland Park petitioners. For Kansas Department of Revenue administrative work, we file Kansas Form K-2848 Power of Attorney and handle the matter remotely. For Kansas Board of Tax Appeals administrative proceedings, we appear under K-2848 where appropriate; for formal litigation appealing a BOTA decision to the Kansas Court of Appeals or the Kansas Supreme Court, we co-counsel with locally admitted Kansas attorneys. For California FTB departing-resident audits, our California Bar admission gives the direct advantage. Most engagements — audit defense, OIC, IA, levy release, Tax Court, RSU cleanup, FBAR Streamlined — are federal and stay entirely with our firm.
I have foreign bank accounts (India, Korea, China, Vietnam) — do I need to file FBAR?
Yes if the aggregate balance of all foreign financial accounts you had signature or financial-interest authority over exceeded $10,000 at any point during the calendar year. FinCEN Form 114 (FBAR) is filed under 31 U.S.C. § 5314 by April 15 with an automatic six-month extension to October 15. IRC § 6038D adds Form 8938 (Statement of Specified Foreign Financial Assets) attached to the Form 1040 above the threshold (varies by filing status and U.S./foreign residence). Past non-compliance can be cleaned up through IRS Streamlined Filing Compliance Procedures (Domestic if you lived in the U.S. each of the past three years, Foreign if you lived abroad) for non-willful taxpayers; willful FBAR penalties under 31 U.S.C. § 5321 reach the greater of $100,000 or 50% of the highest account balance per violation per year. Johnson County's large Indian-American, Korean-American, Chinese-American, and Vietnamese-American H-1B and L-1 community sits at the center of this work.
I am a Johnson County physician with 1099 hospitalist income — what should I be doing?
Physician 1099 income arrives with no withholding, leaving the physician responsible for federal income tax at marginal rate (32% to 37% in most Johnson County hospitalist cases), federal self-employment tax under IRC § 1401 (15.3% on the first $176,100 in 2026, plus 2.9% Medicare and 0.9% Additional Medicare Tax above), and Kansas 5.7% PIT. On $300,000 of 1099 hospitalist income, the total liability runs $130,000 to $145,000. Quarterly Form 1040-ES payments under IRC § 6654 prevent the underpayment penalty. SEP-IRA or solo 401(k) contributions reduce the SE-tax base meaningfully (defined-benefit plans for high-earner physicians can shelter $200,000+ in pre-tax contributions). IRC § 199A qualified-business-income analysis applies but physician practices are specified service trades or businesses subject to the high-income phase-out. We handle the back-balance resolution and the going-forward structure.
What is the Kansas Board of Tax Appeals and what is its deadline?
The Kansas Board of Tax Appeals (BOTA) is an independent state administrative tribunal that hears tax appeals from the Kansas Department of Revenue and county property-tax appeals. Established under K.S.A. § 74-2433, it sits at the Eisenhower State Office Building, 700 SW Harrison Street, Suite 1022, Topeka. The petition deadline is 30 days from KDOR's final determination under K.S.A. § 74-2438 — materially shorter than the federal 90-day Tax Court deadline. BOTA decisions are further appealable to the Kansas Court of Appeals within the time allowed by Kansas appellate rules. Victory Tax Lawyers handles BOTA administrative work under Kansas Form K-2848 Power of Attorney; for appeal to the Kansas Court of Appeals we refer to locally admitted Kansas counsel.
What is Kansas's collection statute of limitations — and how does it compare to California's?
K.S.A. § 79-3230 gives the Kansas Department of Revenue three years from the return due date to assess Kansas income tax (with longer windows for substantial understatement and no limit on fraud or unfiled returns). Once an assessment is final and a Kansas tax warrant has been filed in the Johnson County District Court under K.S.A. § 79-3233f, collection continues until the debt is paid or extinguished. California, in contrast, gives the FTB 20 years from assessment / abatement / lien filing under R&TC § 19255 — meaning a Bay Area relocator who carries a California FTB residency-audit assessment can face California collection for two decades after the move. Illinois's collection statute under 35 ILCS 735/5-22 also runs 20 years. For Overland Park taxpayers with departing-state exposure, the state-collection clock is often the longest-running risk.
Does Kansas offer an Offer in Compromise equivalent to the federal program?
Kansas does not run a published OIC program with the same procedural form as the federal IRC § 7122 program. Instead, the Kansas Department of Revenue accepts settlement and abatement submissions through the Secretary's discretionary authority and the refund-and-credit framework of K.S.A. § 79-3233. The standards parallel federal IRC § 7122 analysis — doubt as to liability, doubt as to collectibility, and economic hardship — but with state-specific procedural rules and no fixed application form. All Kansas returns must be filed before consideration, and a financial-disclosure package is required. We typically run a Kansas settlement filing in parallel with a federal Offer where both debts are real, and add the California FTB or Illinois DOR settlement track where the departing-state assessment is also live.
Can I be audited by both the IRS and the Kansas DOR for the same year?
Yes. The IRS and the Kansas Department of Revenue operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to Kansas under the state's federal-change reporting rule (K.S.A. § 79-32,206), and vice versa. For an Overland Park relocator, add the departing-state layer: California, Illinois, or New York can also be running a residency audit on the same return year. We coordinate every audit on the same timeline to prevent inconsistent positions across the federal record, the Kansas K-40, the departing-state return, and the KCMO RD-109 (if applicable).
Does Kansas have an estate tax?
No. Kansas has no state estate tax and no state inheritance tax. The Kansas estate tax was repealed effective for deaths after December 31, 2009. Federal estate tax under IRC § 2001 still applies to estates exceeding the federal basic exclusion ($13.99 million for 2025, indexed). For Overland Park families that relocated from a state with an active estate tax (Illinois retains an estate tax with a $4 million exclusion under 35 ILCS 405; New York retains a graduated estate tax under N.Y. Tax Law Art. 26; California has no state estate tax), the move to Kansas materially simplifies estate planning at the state level.
Can the IRS levy my T-Mobile or NetSmart wages if I owe federal tax?
Yes. Active employment income is subject to federal tax levy under IRC § 6331. The IRS issues a Form 668-W wage levy to the employer (T-Mobile US payroll, NetSmart Technologies, Applebee's / Dine Brands, Overland Park Regional Medical Center, Saint Luke's South, Johnson County government, USD 229 Blue Valley or USD 512 Shawnee Mission school district payroll), which then withholds at the applicable rate from the Leave and Earnings Statement equivalent. We move to release the levy under IRC § 6343 economic hardship, substitute an installment agreement under IRC § 6159, or challenge procedural defects through Collection Due Process under IRC § 6330 within the 30-day CDP window. RSU vesting events that occur during an active levy can be partially protected through documented economic-hardship filings.
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, including T-Mobile and former Sprint employees, Bay Area and Chicago relocators, and Johnson County physicians and professionals in Overland Park.
Page last reviewed: . Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Kansas statute citation references the Kansas Statutes Annotated. 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 Kansas Department of Revenue, the California Franchise Tax Board, the Illinois Department of Revenue, the Kansas Board of Tax Appeals, the U.S. 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 Kansas, Missouri, or Illinois; where a Kansas, Missouri, or Illinois state-court appearance or Kansas Court of Appeals 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
Kansas state hub
Statewide KS practice
Kansas City metro
KCMO & KCK coverage
Manhattan KS
K-State / Fort Riley
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. § 83 — Property Transferred for Services (RSU and §83(b) election)
- 26 U.S.C. § 55 — Alternative Minimum Tax (ISO exercise spread)
- 26 U.S.C. § 107 — Clergy housing allowance
- 26 U.S.C. § 117 — Qualified scholarships and §117(c) service exception
- 26 U.S.C. § 199A — Qualified Business Income deduction
- 26 U.S.C. § 6038D — Form 8938 specified foreign financial asset reporting
- 31 U.S.C. § 5314 — FBAR (FinCEN Form 114) reporting
- 31 U.S.C. § 5321 — FBAR penalties
- K.S.A. § 79-32,110 — Kansas graduated personal income tax (3.10% to 5.7%) and graduated Corporate Income Tax (4% to 7%)
- K.S.A. § 79-32,111 — Kansas credit for tax paid to another state (reciprocity for MO PIT, not KCMO 1%)
- K.S.A. § 79-32,206 — Kansas federal-change reporting rule
- K.S.A. § 79-3226 — Kansas Notice of Assessment
- K.S.A. § 79-3228 — Kansas failure-to-file and failure-to-pay penalties
- K.S.A. § 79-3230 — Kansas assessment statute of limitations
- K.S.A. § 79-3233 — Kansas refund and credit framework
- K.S.A. § 79-3233f — Kansas tax warrant in District Court
- K.S.A. § 79-3234 — Kansas responsible-person liability for withheld tax
- K.S.A. § 79-3603 — Kansas state sales tax (6.5%)
- K.S.A. § 79-3617 — Kansas sales-tax responsible-person liability
- K.S.A. § 74-2433 — Kansas Board of Tax Appeals (BOTA) establishment
- K.S.A. § 74-2438 — Kansas BOTA 30-day petition window
- HB 2106 (2022) — Kansas grocery sales-tax phase-down
- KCMO Ordinance 68-381 — Kansas City Missouri 1% earnings tax (non-resident commuter)
- R&TC § 17014 — California residency factors (FTB departing-resident audits)
- R&TC § 19255 — California 20-year collection statute
- 35 ILCS 5/201 — Illinois flat 4.95% individual income tax
- 35 ILCS 735/5-22 — Illinois 20-year collection statute