Tax Attorney in Pennsylvania

Yes. Pennsylvania imposes a flat personal income tax of 3.07% on most types of income under 72 Pa. C.S. §7302, with no graduated brackets and no standard deduction. The rate has been stable since 2004. Pennsylvania taxes eight specific classes of income (compensation, interest, dividends, net profits from business, net gains from property dispositions, rents, gambling and lottery winnings, and estates and trusts) and does not allow most federal itemized deductions. The corporate net income tax is 7.49% for 2026 and continues phasing down by half a point each year until reaching 4.99% in 2031. Philadelphia layers a city wage tax on top, and Pittsburgh imposes a 3% local services and earned-income tax.

The U.S. Tax Court holds permanent-courtroom trial sessions at the U.S. Custom House (200 Chestnut Street, Philadelphia, Room 300) and the William S. Moorhead Federal Building (1000 Liberty Avenue, Pittsburgh, Room 1108). A petitioner designates the preferred place of trial on the petition under Tax Court Rule 140. Eastern Pennsylvania filers from the Philadelphia, Reading, Allentown, Bethlehem, and Lancaster regions typically calendar to Philadelphia. Western Pennsylvania filers from Pittsburgh, Erie, Johnstown, and the Marcellus Shale gas counties typically calendar to Pittsburgh. Central Pennsylvania filers in Harrisburg, Scranton, and Williamsport choose between the two based on distance.

Under 72 P.S. §7348 for personal income tax, the Pennsylvania Department of Revenue generally has three years from the date the return was filed to assess additional tax. The period extends to six years if more than 25% of gross income was omitted, and there is no limit where the return was fraudulent or never filed. Pennsylvania's collection period under 72 P.S. §7202.1 generally runs ten years from assessment, paralleling the federal CSED under IRC §6502. State and federal clocks run separately.

Yes, but they audit different taxes. The IRS examines federal income tax, federal employment tax, and federal excise tax. The Pennsylvania Department of Revenue examines state personal income tax, corporate net income tax, sales-and-use tax, employer withholding, and inheritance tax. A Pennsylvania filer can simultaneously face an IRS Schedule C audit and a PA DOR PA-40 audit on the same income. The two agencies share information through information-exchange agreements with the IRS, and a federal adjustment to AGI typically triggers a parallel state adjustment because Pennsylvania uses federal classes of income as the starting point.

Pennsylvania offers a Deferred Payment Plan through the Department of Revenue and may settle disputed liabilities through the Board of Appeals compromise process under 72 P.S. §9702. The state does not run a formal OIC program identical to the federal IRS under IRC §7122, but the Board of Appeals has authority to compromise where the liability is genuinely doubtful or collectibility is impaired. Penalty waivers may be granted under 72 P.S. §353 where reasonable cause exists. For the federal side, the IRS OIC remains the standard mechanism for resolving a federal tax balance for less than the full amount.

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

Probably yes for the federal trust-fund portion. IRC §6672 assesses a Trust Fund Recovery Penalty against any "responsible person" who "willfully" failed to pay over withheld taxes — the FICA and federal income-tax withholding portion of Form 941, not the employer's share. The IRS conducts a Form 4180 interview to identify responsible persons. Anyone with check-signing authority, payroll-decision authority, or knowledge of the unpaid taxes can be assessed. On the state side, Pennsylvania employer withholding tax and Pennsylvania sales-tax responsible-person liability under 72 P.S. §7268 operate under similar principles for individuals collecting tax in trust.

Yes. IRC §7345 authorizes the IRS to certify "seriously delinquent" tax debt — currently $62,000 for 2026, indexed for inflation — to the State Department, which may then deny passport renewal or revoke an active passport. The certification reverses when the debt is paid, an IA is in place, an accepted OIC is in force, an active CDP hearing is pending, or Innocent Spouse Relief is in process. For Pennsylvania pharmaceutical executives traveling to Europe, Marcellus Shale engineers heading to Canada, and academic researchers in Philadelphia and Pittsburgh with international conferences, decertification is often urgent and can be processed in 30 days or less.

Pennsylvania is one of only six states that still impose a state inheritance tax. Under 72 P.S. §9116, the rates are 0% for transfers to a surviving spouse and to children age 21 or under from a parent, 4.5% for transfers to direct descendants and lineal heirs (children, grandchildren), 12% for transfers to siblings, and 15% for transfers to other heirs (cousins, friends, unrelated beneficiaries). The return is the REV-1500, filed with the Register of Wills in the county where the decedent resided, and is due within nine months of death. A 5% discount applies if paid within three months. Federal estate tax may apply separately if the gross estate exceeds the federal exclusion threshold.

Philadelphia is unusual in that it has its own Department of Revenue separate from the Pennsylvania Department of Revenue. The city imposes a wage tax of 3.75% on residents and 3.44% on nonresidents working in Philadelphia (2026 rates), plus the Business Income and Receipts Tax (BIRT), Net Profits Tax for self-employed residents, and Use and Occupancy Tax on commercial tenants. Philadelphia tax collection runs independently — the city can file its own warrants and seize bank accounts without IRS or PA DOR involvement. When a federal IRS case lands on a Center City business owner, there is often a parallel Philadelphia Department of Revenue collection running at the same time. We coordinate the federal posture; Philadelphia counsel handles the city side.

Federal tax-resolution fees vary by matter complexity. A straightforward Installment Agreement typically falls between $1,500 and $3,500. A full Offer in Compromise with Form 433 financial analysis runs $4,000 to $7,500. Audit defense depends on the audit type and the number of issues. A U.S. Tax Court petition with case workup and trial preparation generally starts at $6,000 and rises with complexity. VTL provides a written fee quote after the free consultation. Cal Bar Rule 7.1 prohibits comparisons claiming we are cheaper or faster than competitors without verifiable substantiation, so we do not market on price.

Yes. Communications between you and a licensed attorney for the purpose of seeking legal advice are protected by federal common-law attorney-client privilege, subject to the usual exceptions (crime-fraud, waiver, etc.). The narrower federally-authorized tax practitioner privilege under IRC §7525 applies to non-attorney CPAs and EAs but does not extend to criminal-tax matters. An attorney handling your tax case retains the broader privilege that survives criminal investigation.

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

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

For administrative proceedings at the Pennsylvania Board of Appeals and the Board of Finance and Revenue, taxpayers may represent themselves or be represented by an attorney, a CPA, or another authorized representative under Pennsylvania DOR rules. For appeal to the Pennsylvania Commonwealth Court — the state's intermediate appellate court for tax matters — an attorney admitted in Pennsylvania is required. VTL handles the federal side of overlapping matters and coordinates with Pennsylvania counsel where Commonwealth Court litigation is necessary. Many state tax disputes resolve at the Board of Appeals stage without ever reaching Commonwealth Court.