Tax Attorney in Pittsburgh, PA

Federal IRS representation for Pittsburgh individuals and businesses — audits, back taxes, liens, levies, payroll-tax disputes, and U.S. Tax Court litigation at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street. We also coordinate Pennsylvania Department of Revenue matters under PA Form REV-677 Power of Attorney where they sit alongside a federal case.

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

Call (800) 883-8301 Free Consultation

Serving Pittsburgh, Allegheny County, the Mon Valley, Moon Township, Cranberry, Squirrel Hill, Oakland, and Western Pennsylvania

$100M+

in tax relief secured

2,000+

resolved cases

5.0 / 72

Google reviews

U.S. Tax Court

admitted counsel

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

Pennsylvania carries a flat 3.07% personal income tax under 72 Pa.C.S. § 304 — one of the lowest flat rates in the country — but Pittsburgh stacks a Local Earned Income Tax of 3% on resident wages (1% to the City of Pittsburgh and 2% to the Pittsburgh Public School District) under Pittsburgh Code Title 2 Article VII Chapter 245, plus a $52 annual Local Services Tax. A Pittsburgh resident pays an effective combined state-plus-local rate of roughly 6.07% on wage income before federal tax even enters the picture. Pennsylvania also imposes an inheritance tax at 4.5% on transfers to lineal descendants, 12% on transfers to siblings, and 15% on transfers to non-relatives under 72 Pa.C.S. § 9116 — one of only six states that still levies a separate inheritance tax. Stack that on the 37% federal top rate and a UPMC physician, a PNC executive, a Duolingo equity-vest year, or a Steelers, Penguins, or Pirates contract can produce a six- or seven-figure tax exposure in a single year.

If you have received an IRS CP504, LT11, or Statutory Notice of Deficiency, or if the Pennsylvania Department of Revenue has issued a Notice of Assessment with proposed tax, penalty, and interest, the deadline to act is short. We pull your IRS account transcripts, calculate your CSED, file Form 2848 with the IRS and Form REV-677 with the PA DOR, and put administrative brakes on collection while the case is built.

Federal tax representation for Pittsburgh taxpayers

Victory Tax Lawyers, LLP is a California-Bar-admitted tax-resolution law firm based in Los Angeles. Our federal practice runs nationwide: the Internal Revenue Service accepts our Form 2848 Power of Attorney in every state, and the U.S. Tax Court — a single federal tribunal with jurisdiction over IRS deficiency cases — holds regular trial sessions in Pittsburgh at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street. Pittsburgh is the primary U.S. Tax Court trial city for Western Pennsylvania, drawing petitioners from Allegheny, Butler, Beaver, Washington, Westmoreland, Fayette, Greene, and Lawrence counties. From our Robertson Boulevard office in Los Angeles, we represent Pittsburgh residents and Pennsylvania-domiciled businesses in IRS audits, collection cases, Tax Court petitions, Offers in Compromise under IRC § 7122, Installment Agreements under IRC § 6159, lien discharges under IRC § 6325, levy releases under IRC § 6343, and Trust Fund Recovery Penalty defenses under IRC § 6672.

For Pennsylvania state tax matters — the flat 3.07% personal income tax under 72 Pa.C.S. § 304, the 8.99% corporate net income tax (phasing down to 4.99% by 2031) under 72 Pa.C.S. § 7401, the 4.5% / 12% / 15% Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116, the 6% state sales-and-use tax plus the 1% Allegheny County local sales tax (7% combined in Pittsburgh) under 72 Pa.C.S. § 7202, withholding-tax assessments, or contested matters headed to the Pennsylvania Board of Finance and Revenue — we file PA Form REV-677 with the Department of Revenue and handle the administrative track directly. For formal litigation before the Pennsylvania Commonwealth Court (which sits in Harrisburg at 601 Commonwealth Avenue, Suite 2100, and hears tax appeals from the Board of Finance and Revenue) or the Pennsylvania Supreme Court, we refer to locally admitted Pennsylvania counsel under a co-counsel arrangement. The federal layer is where most Pittsburgh UPMC physician, biotech, AV-tech, and financial-services cases live, and that is where our engagement carries the load.

Pittsburgh sits at the center of a Western Pennsylvania economy built on three distinct waves: the steel-and-aluminum legacy of U.S. Steel (still headquartered downtown at 600 Grant Street), Allegheny Technologies (ATI), Arconic, and Alcoa; the modern financial-services and corporate-headquarters cluster of PNC Financial Services Group (headquartered at One PNC Plaza), Heinz (now Kraft Heinz), Mylan (now Viatris), Dick's Sporting Goods (headquartered in Coraopolis), and FedEx Ground (Moon Township); and the academic-and-technology engine of the University of Pittsburgh Medical Center (UPMC, the largest non-government employer in Pennsylvania and the largest academic medical center in the United States), Carnegie Mellon University, the University of Pittsburgh, Duolingo (headquartered downtown), Aurora Innovation, the Argo AI legacy, and the Uber Advanced Technologies Group autonomous-vehicle history. Add Steelers, Penguins, and Pirates pro-athlete payrolls; Polish, Italian, Slovak, Croatian, and Hungarian Eastern European family-business networks across the Mon Valley and the South Side; the Squirrel Hill Jewish community (the largest per-capita Jewish community in the United States); and a growing Indian-American FBAR-exposure population around Oakland and the South Hills, and the tax-resolution footprint is high-W-2-equity-compensation, 1099 physician underwithholding, § 1202 Qualified Small Business Stock for CMU and Pitt spin-outs, § 174 R&D capitalization for AI and robotics labs, § 6672 Trust Fund Recovery Penalty heritage from the steel-mill era, and FinCEN Form 114 work on overseas family accounts. The federal procedures are uniform; the facts are Pittsburgh-specific.

Your tax rights as a Pittsburgh taxpayer

Two parallel rights frameworks apply when you owe tax. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from the Pennsylvania Consolidated Statutes Title 72, the Department of Revenue's Taxpayer Rights Advocate office, and the procedural rules of the Pennsylvania Board of Finance and Revenue. Knowing both is the difference between a clean resolution and a missed 60-day Board of Finance and Revenue petition window that locks in a state assessment against your Squirrel Hill, Shadyside, or Sewickley 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. Pennsylvania mirrors this through PA Form REV-677 Power of Attorney, accepted for all Department of Revenue matters.

Right to U.S. Tax Court review

IRC § 6213(a) gives you 90 days from a Statutory Notice of Deficiency to petition the U.S. Tax Court without paying the tax first. Miss the 90 days and the federal assessment becomes final. The U.S. Tax Court holds regular trial sessions in Pittsburgh at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street — the primary Western Pennsylvania trial city.

Right to PA Board of Finance and Revenue review

72 Pa.C.S. § 9702 and the Board's procedural rules give you 60 days from a final PA Department of Revenue Board of Appeals decision to file a petition with the Pennsylvania Board of Finance and Revenue at 1101 South Front Street, Suite 400, Harrisburg. The 60-day window is shorter than the federal 90-day Tax Court deadline. Missing it forfeits the right to administrative review of the state assessment before judicial appeal to the Pennsylvania Commonwealth Court.

Collection Due Process

IRC § 6320 (lien) and IRC § 6330 (levy) give you a 30-day window to request a CDP hearing once the IRS files a Notice of Federal Tax Lien or issues a Final Notice of Intent to Levy. A timely CDP filing halts collection and preserves judicial review through the U.S. Tax Court.

Right to settle for less than owed

Federally, IRC § 7122 authorizes Offers in Compromise based on doubt as to liability, doubt as to collectibility, or effective tax administration. Pennsylvania runs a Deferred Payment Plan program and a more selective Compromise program under 72 Pa.C.S. § 9707 administered by the PA DOR, with hardship and insolvency standards similar to but tighter than the federal framework. Both programs require all returns filed and current-year compliance before consideration.

Right to recover fees

IRC § 7430 allows recovery of administrative and litigation costs if the IRS takes a position that is not substantially justified and the taxpayer prevails. The threshold is high, but real, especially in audit reconsideration and Innocent Spouse cases under IRC § 6015.

How Victory Tax Lawyers helps Pittsburgh 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 Pittsburgh taxpayers carrying a parallel Pennsylvania liability, we coordinate a PA Compromise petition under 72 Pa.C.S. § 9707 with the DOR on the same financial showing, sequencing the two programs so an accepted federal Offer does not break a pending state offer or vice versa.

Installment Agreements under IRC § 6159

Streamlined IAs (under $50,000), partial-pay IAs under IRC § 6159(d), and full-pay agreements. We push for partial-pay structures where the IRC § 6502 ten-year CSED will extinguish the balance before payoff — the most under-used resolution path for Pittsburgh taxpayers carrying between $50,000 and $250,000 in federal debt, particularly UPMC 1099 physicians who never made quarterly payments, Duolingo and Argo AI alumni with concentrated RSU vests, and steel-industry retirees who took early lump-sum pension distributions.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a Pittsburgh property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs filed with the Allegheny County Department of Real Estate (also known as the Recorder of Deeds), Frick Building, 437 Grant Street, encumber title on Squirrel Hill, Shadyside, Mt. Lebanon, Sewickley, Fox Chapel, Upper St. Clair, Cranberry, and Mt. Washington properties; the IRS procedures under IRC § 6325 set the cure path. Timing must align with the closing date.

Levy release under IRC § 6343

Wage levies, bank levies, and accounts-receivable levies. We document economic hardship under IRC § 6343(a)(1)(D) and Treasury Reg. § 301.6343-1(b)(4), and where the levy is procedurally defective, we challenge it through Collection Due Process or Appeals. Pennsylvania state tax liens follow a parallel track under 72 Pa.C.S. § 7805 and are recorded in the Prothonotary's office for the county where the taxpayer holds real property; in Pittsburgh that is the Allegheny County Prothonotary in the City-County Building, 414 Grant Street.

Audit defense and U.S. Tax Court litigation

Correspondence audits, office audits, and field examinations — including sensitive issues like cryptocurrency, foreign accounts under FinCEN Form 114 (FBAR), S-corporation reasonable-compensation, § 83(b) election validity, § 1202 Qualified Small Business Stock claims for Carnegie Mellon and Pitt biotech and robotics spin-outs, § 174 R&D capitalization timing for CMU Robotics Institute and AI-research contractors, and § 1061 three-year carried-interest holding periods. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Pittsburgh trial sessions are held at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street.

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. Pennsylvania penalties under 72 Pa.C.S. § 352 (failure to file) and § 353 (failure to pay) follow a separate reasonable-cause analysis applied by the PA DOR and reviewable by the Board of Appeals and then the Board of Finance and Revenue.

Twelve types of Pittsburgh tax matters we handle

Federal cases for Pittsburgh residents and businesses, framed against the PA DOR and Pittsburgh local-tax overlay where it matters.

UPMC 1099 physician underwithholding

The University of Pittsburgh Medical Center is the largest non-government employer in Pennsylvania and the largest academic medical center in the United States. UPMC attending physicians, surgical specialists, anesthesiologists, and pathologists frequently carry side 1099 income from independent surgical centers, telemedicine, clinical-trial honoraria, and pharmaceutical-royalty arrangements. The federal Schedule C self-employment exposure plus 15.3% SECA under IRC § 1401, the Pennsylvania 3.07% PIT, and the Pittsburgh 3% Local Earned Income Tax on resident wages can land a UPMC physician with a five- or six-figure balance due the spring after a strong year.

Pennsylvania Inheritance Tax exposure

72 Pa.C.S. § 9116 imposes the Pennsylvania Inheritance Tax at 4.5% on transfers to lineal descendants (children, grandchildren), 12% on transfers to siblings, and 15% on transfers to nieces, nephews, and non-relatives. Pennsylvania is one of only six states still imposing a separate inheritance tax (Iowa is phasing its out, leaving five by 2025). Squirrel Hill, Shadyside, Sewickley, Fox Chapel, and Mt. Lebanon estate values regularly cross the threshold where the 4.5% tax adds up to a meaningful number, particularly when sibling transfers (12%) or non-relative bequests (15%) come into play. Form REV-1500 is due within nine months of death; a 5% discount is available for prepayment within three months.

Trust Fund Recovery Penalty — steel-industry heritage

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Pittsburgh carries a long Trust Fund Recovery Penalty heritage from the steel and manufacturing era — modern targets are restaurant owners (Strip District, South Side, Lawrenceville), construction firms, healthcare staffing companies, and small manufacturers across the Mon Valley. The IRS uses Form 4180 interviews to identify responsible persons. Pennsylvania applies a parallel responsible-person rule to withheld state income tax and sales tax under 72 Pa.C.S. § 7240.

Carnegie Mellon and Pitt § 174 R&D capitalization

The 2017 Tax Cuts and Jobs Act amendment to IRC § 174 (effective tax year 2022) requires capitalization and five-year amortization of domestic research and experimental expenditures — 15-year for foreign R&D. Carnegie Mellon Robotics Institute spin-outs, Pitt biotech and bioengineering startups, AI-research contractors, autonomous-vehicle developers (Aurora, the Argo AI legacy, Uber ATG legacy), and Pittsburgh's growing AI-startup cluster carry substantial § 174 exposure. The mismatch between book expense recognition and tax capitalization regularly produces unexpected federal balances on Form 1120, 1120-S, and 1065 returns.

Notice of Federal Tax Lien

NFTLs filed with the Allegheny County Department of Real Estate (Recorder of Deeds), Frick Building, 437 Grant Street, encumber title and trigger CDP rights under IRC § 6320. A parallel Pennsylvania state tax lien may be recorded under 72 Pa.C.S. § 7805 in the Prothonotary's office for the county where the taxpayer holds real property. Squirrel Hill, Shadyside, Mt. Lebanon, Sewickley, Fox Chapel, Upper St. Clair, Cranberry, and Strip District closings stall fast when an NFTL hits the title search.

IRS bank or wage levy

Bank levies on accounts held at PNC Bank (Pittsburgh-headquartered), First National Bank of Pennsylvania (FNB), Dollar Bank, Citizens, S&T Bank, Northwest Bank, or any Pennsylvania-chartered institution. Wage levies hit Pittsburgh employers within days of CP90 or LT11 issuance — including UPMC, PNC, Highmark Health, BNY Mellon (Pittsburgh operations), Duolingo, U.S. Steel, ATI, Arconic, Heinz, Dick's Sporting Goods, FedEx Ground, Carnegie Mellon, and the University of Pittsburgh.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. With Pittsburgh International Airport serving international routes, a UPMC physician travel population, Pitt and CMU international faculty and researchers, and dual-citizen Indian-American, Polish-American, and Italian-American family-business owners across Squirrel Hill, Bloomfield, and the South Hills, this lands hard. We file the IRC § 7345(e) action to reverse the certification.

FBAR and FATCA non-disclosure

FinCEN Form 114 for foreign accounts over $10,000 aggregate. Pittsburgh's Polish, Italian, Slovak, Croatian, Hungarian, and Serbian Eastern European communities (Polish Hill, Bloomfield, the South Side, the Mon Valley boroughs of McKeesport, Duquesne, Clairton, and Homestead), the Squirrel Hill Jewish community (the largest per-capita Jewish community in the United States, with steady Israeli and European-account exposure), and the growing Indian-American community around Oakland, Monroeville, and the South Hills all carry steady FBAR exposure on inherited or family-business overseas accounts. The IRS Streamlined Filing Compliance Procedures are a frequent engagement.

Pittsburgh Local Earned Income Tax disputes

Pittsburgh Code Title 2 Article VII Chapter 245 imposes a 3% Local Earned Income Tax on resident wages (1% to the City of Pittsburgh, 2% to the Pittsburgh Public School District) and a 1% non-resident LST on wages earned in the City by non-residents. The tax is administered by Jordan Tax Service on behalf of the City of Pittsburgh Department of Finance, 414 Grant Street, Room 414. Disputes over residency (Mt. Lebanon vs. City of Pittsburgh, Wilkinsburg vs. Pittsburgh, Edgewood vs. Pittsburgh), reciprocal-credit calculations for residents working in non-PA states, and remote-work allocations since 2020 are a recurring assessment driver.

Innocent Spouse Relief

IRC § 6015 relief for spouses jointly liable on a return where the other spouse's items caused the deficiency. We file Form 8857 with a clean factual record — common in divorces involving UPMC physicians with side practices, PNC and BNY Mellon executives with concentrated equity, Duolingo founders and equity-holders, and small-business owners whose K-1 income surprised the other spouse.

Pro-athlete jock-tax exposure

Pittsburgh Steelers, Penguins, and Pirates players carry multi-state jock-tax exposure on duty-day allocations across every away city. Pennsylvania's 3.07% flat PIT plus the Pittsburgh 3% resident Local Earned Income Tax produces a roughly 6.07% combined home-state rate — lower than New York or California but higher than no-state-tax jurisdictions. Visiting players also pay the 1% Pittsburgh non-resident LST on duty-day wages earned in the City. Equity and signing-bonus allocations, residency-tiebreaker analysis under the substantial-presence and domicile tests, and PA Schedule G-L resident-credit calculations are recurring engagements.

Cryptocurrency tax assessments

CP2000 notices on unreported digital-asset gains, basis-tracking failures, and DeFi-protocol income. Pittsburgh's CMU, Pitt, and tech-startup technical population picked up substantial crypto exposure through 2021-2024. Form 1099-DA reporting (effective 2025) drives the matching cases. Pennsylvania treats virtual-currency gains as taxable under the 3.07% flat PIT and reportable on the Schedule D of PA-40, with no preferential capital-gain rate at the state level.

Nine common causes of tax debt for Pittsburgh taxpayers

Patterns we see repeatedly in Pittsburgh-based engagements. None of them are unusual — all of them are resolvable.

1. Underwithheld RSU and ISO vest events

A Duolingo, PNC, BNY Mellon, Highmark, or post-IPO tech-startup employee at the 35% or 37% federal marginal bracket sees only 22% supplemental withholding on RSU vests. The shortfall, plus 3.07% Pennsylvania and the 3% Pittsburgh resident Local Earned Income Tax, produces a five- or six-figure balance due the following April.

2. Self-employment underpayment

UPMC attending physicians with private 1099 practices, Allegheny Health Network specialists, Carnegie Mellon and University of Pittsburgh adjunct faculty, K&L Gates and Reed Smith of-counsel attorneys, real-estate agents, and Mon Valley tradespeople file Schedule C or K-1 income with no estimated-tax payments. The first IRS CP14 lands the following spring with penalties under IRC § 6654.

3. Business closure

When an LLC, S-corp, or early-stage CMU or Pitt spin-out closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Common in the AV-tech and AI-startup failure cycle that produced the Argo AI wind-down and a wave of follow-on shutdowns.

4. Divorce and joint-return fallout

A jointly-filed return tied to a now-former spouse's understatement leaves both parties liable until Innocent Spouse relief under IRC § 6015 is granted.

5. Identity theft and fraudulent returns

A return filed in your name with refund redirected. Form 14039 opens the IRS identity-theft case; the assessment must be corrected, not just protested. Pennsylvania has its own DOR identity-theft and Fraud Investigation Unit that runs in parallel.

6. Cryptocurrency CP2000 surprise

Exchanges issue Form 1099-DA (introduced 2025), and the IRS computer matches reported gains. Missed basis records turn into ordinary-income assessments at the full sale price.

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. Pennsylvania mirrors the federal three-year refund bar under 72 Pa.C.S. § 346.

8. Real-estate sale without estimated tax

A Squirrel Hill, Shadyside, Fox Chapel, Sewickley, or Lawrenceville sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Pennsylvania taxes the gain at the flat 3.07% rate with no separate capital-gain category. Pittsburgh resident sellers also owe the 3% Local Earned Income Tax on the gain only if it is characterized as earned income (typically dealer-status under IRC § 1221), not investment income.

9. Stock-option exercise without planning

ISO disqualifying dispositions and NSO ordinary-income inclusions hit Pittsburgh tech, financial-services, and biotech employees with AMT under IRC § 55 and large balances due. IRC § 83(b) elections missed within the 30-day window create their own irreversible problem — especially costly for Duolingo, Aurora, Astrobotic, and CMU Robotics Institute spin-out founders whose early-grant basis was low and whose § 1202 QSBS holding period depends on a valid election.

Eight tax liabilities that pull in Pittsburgh taxpayers

Federal authority alongside the Pennsylvania statute where there is a parallel.

Failure to file federal return

IRC § 6651(a)(1) imposes 5% per month, capped at 25%, plus interest under IRC § 6601. The Pennsylvania mirror is 72 Pa.C.S. § 352 imposing a 5% per month late-filing penalty (minimum $5, capped at 25%) on unpaid Pennsylvania tax.

Failure to file Pennsylvania return

72 Pa.C.S. § 352 imposes a 5% per month penalty on the unpaid tax for failure to file, capped at 25%, plus interest under 72 Pa.C.S. § 806. The PA DOR may issue a Notice of Assessment triggering an internal Board of Appeals window, with further review by the Pennsylvania Board of Finance and Revenue under 72 Pa.C.S. § 9702 within 60 days of the Board of Appeals decision.

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.

Pennsylvania sales-tax delinquency

72 Pa.C.S. § 7202 sets the 6% state sales tax on retail sales of tangible personal property and certain enumerated services. Allegheny County adds a 1% local sales tax (Pittsburgh combined rate 7%); Philadelphia adds 2%. 72 Pa.C.S. § 7240 imposes personal liability on responsible persons for unpaid trust-fund sales tax. The Pennsylvania use tax under 72 Pa.C.S. § 7202 is aggressively enforced against businesses purchasing equipment out of state.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Pennsylvania applies a parallel responsible-person rule to withheld state income tax and sales tax under 72 Pa.C.S. § 7240. Pittsburgh's steel-mill-era enforcement legacy continues today against restaurant, hospitality, healthcare-staffing, and small-manufacturing owners across Allegheny County.

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. 72 Pa.C.S. § 353 imposes a parallel underpayment penalty at the state level.

Pennsylvania Inheritance Tax

72 Pa.C.S. § 9116 imposes Pennsylvania Inheritance Tax at 4.5% on transfers to lineal descendants, 12% on transfers to siblings, and 15% on transfers to non-relatives. Pennsylvania is one of only six states that still imposes a separate inheritance tax. Form REV-1500 is filed with the Pennsylvania Register of Wills (in Pittsburgh that is the Allegheny County Register of Wills, City-County Building, 414 Grant Street, Room 327) within nine months of death; a 5% discount is available for prepayment within three months of death.

Transferee liability

IRC § 6901 lets the IRS pursue a transferee — a person who received property from a delinquent taxpayer — for the transferor's unpaid tax, up to the value of the transferred property.

What resolution can look like

Debt reduced

An accepted IRC § 7122 Offer in Compromise can resolve six-figure balances for cents on the dollar where Reasonable Collection Potential supports the offer. The acceptance rate sits around 33% nationally; preparation determines the outcome.

Penalties abated

First-Time Abate removes a single year of failure-to-file or failure-to-pay penalties for taxpayers with a clean three-year compliance record. Reasonable-cause abatement under IRM 20.1.1 reaches further when supported by documentation.

Lien released or withdrawn

Once a debt is paid in full, the IRS releases the Notice of Federal Tax Lien within 30 days per IRC § 6325(a). On an Installment Agreement of $25,000 or less, lien withdrawal under Form 12277 can be requested to clear title with the Allegheny County Department of Real Estate.

Sample tax-resolution outcomes

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

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

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

Why Victory Tax Lawyers for a Pittsburgh federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Pennsylvania-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 Pittsburgh at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street. IRS administrative practice runs on Form 2848 Power of Attorney, accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our Pittsburgh clients never need a separately admitted Pennsylvania attorney because the case is, at its core, federal.

For administrative work before the Pennsylvania Department of Revenue — protests, audit responses, Compromise petitions under 72 Pa.C.S. § 9707, and Deferred Payment Plan requests — we file PA Form REV-677 Power of Attorney and handle the matter remotely. When a case must move to the Pennsylvania Board of Finance and Revenue (the state administrative tribunal at 1101 South Front Street, Suite 400, Harrisburg) or appeal further to the Pennsylvania Commonwealth Court (the intermediate appellate court that hears tax appeals from the Board of Finance and Revenue, sitting at 601 Commonwealth Avenue, Suite 2100, Harrisburg) or the Pennsylvania Supreme Court, we coordinate with locally admitted Pennsylvania counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the bigger exposure given UPMC 1099 physician income, Duolingo and tech RSU vests, Carnegie Mellon and Pitt spin-out equity, and steel-industry Trust Fund Recovery Penalty heritage, stays with us.

What distinguishes our firm: a California-Bar-admitted managing attorney with active U.S. Tax Court admission, an Enrolled Agent on staff for IRS administrative work, a 5.0 / 72-review Google rating, and $100M+ in cumulative tax relief secured across 2,000+ resolved matters. No marketing claim of being a Pennsylvania-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Pittsburgh taxpayer, at the same standard we apply to a Los Angeles client. Our 100% remote workflow runs through a secure document portal — you never have to travel to Robertson Boulevard.

Our seven-step process for Pittsburgh 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 and PA Form REV-677 with the Pennsylvania DOR, register on the CAF system, and step in as the contact of record.

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, and identify tolling events.

Strategy memo

A written summary: the resolution path (OIC, IA, CNC, audit response, CDP, Tax Court), the timeline, and the realistic outcome range.

Filing and negotiation

We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, or a PA Board of Finance and Revenue petition through local counsel — and handle every IRS and DOR 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 Pennsylvania's statute

The IRS has ten years from the date of assessment to collect a federal tax under IRC § 6502. After the Collection Statute Expiration Date, the debt is extinguished by operation of law. The clock pauses (“tolls”) when an Offer in Compromise is pending, when a Collection Due Process petition is filed, during bankruptcy, when an installment agreement is requested, and when the taxpayer is outside the United States for six months or more.

Pennsylvania runs a parallel state collection rule under 72 Pa.C.S. § 7805. The PA DOR generally must assess Pennsylvania personal income tax within three years of the return due date (extended for substantial omissions, with no statute on collection in cases of fraud or non-filing). Once a state tax lien is recorded in the Allegheny County Prothonotary's office, it remains effective until satisfied and is renewable under PA law. Many Pittsburgh taxpayers carry a federal CSED that will run out before the Pennsylvania state-lien clock — or vice versa. Pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.

Pittsburgh tax authorities and venues

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

Internal Revenue Service — Pittsburgh TAC

The federal tax authority, at irs.gov. The Pittsburgh Taxpayer Assistance Center operates at the William S. Moorhead Federal Building, 1000 Liberty Avenue, Pittsburgh PA 15222. Appointments required.

U.S. Tax Court — Pittsburgh trial sessions

The U.S. Tax Court holds regular trial sessions in Pittsburgh at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street, Pittsburgh PA 15219. Pittsburgh is the primary Western Pennsylvania trial city, drawing petitioners from Allegheny, Butler, Beaver, Washington, Westmoreland, Fayette, Greene, Lawrence, and surrounding counties. Petitions are filed at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

Pennsylvania Department of Revenue

The state tax authority, at revenue.pa.gov. Headquartered at Strawberry Square, 4th & Walnut Streets, Harrisburg PA 17128, with a Pittsburgh district office at 411 Seventh Avenue, Room 420, Pittsburgh PA 15219. Administers the flat 3.07% personal income tax under 72 Pa.C.S. § 304, the 8.99% corporate net income tax (phasing down) under 72 Pa.C.S. § 7401, the 6% state sales-and-use tax under 72 Pa.C.S. § 7202, withholding tax, and the Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116.

Pennsylvania Board of Finance and Revenue

The state administrative tax appeals tribunal. Seated at 1101 South Front Street, Suite 400, Harrisburg PA 17104. Hears second-level appeals from final decisions of the PA DOR Board of Appeals on personal income tax, corporate net income tax, sales and use tax, employer withholding, and inheritance tax. 60-day petition deadline under 72 Pa.C.S. § 9702 from the Board of Appeals decision. Further appeal lies to the Pennsylvania Commonwealth Court.

Pennsylvania Commonwealth Court

The Commonwealth's intermediate appellate court with original and appellate jurisdiction over Pennsylvania tax appeals. Seated at 601 Commonwealth Avenue, Suite 2100, Harrisburg PA 17120, with hearings also held in Pittsburgh and Philadelphia. Appeals from the Board of Finance and Revenue are filed here under 42 Pa.C.S. § 763. Further appeal lies to the Pennsylvania Supreme Court. Victory Tax Lawyers refers Commonwealth Court litigation to locally admitted Pennsylvania counsel; we handle the federal portion and the PA DOR administrative work directly.

City of Pittsburgh Department of Finance

The municipal finance authority for the City of Pittsburgh. Office at 414 Grant Street, Room 414, Pittsburgh PA 15219. Page: pittsburghpa.gov/finance. Administers the Pittsburgh Local Earned Income Tax (3% resident / 1% non-resident under Pittsburgh Code Title 2 Article VII Ch 245), the $52 annual Local Services Tax, the Payroll Expense Tax on Pittsburgh-located employers, the Amusement Tax, the Parking Tax, and municipal real-estate tax collection. Local Earned Income Tax administration is contracted to Jordan Tax Service for most enforcement purposes.

Allegheny County Treasurer

The county tax-collection authority. Office at 436 Grant Street, Room 108, Pittsburgh PA 15219. Page: alleghenycounty.us. Administers Allegheny County real-estate tax collection, hotel-room rental tax, drink tax (the 7% Allegheny County alcoholic-beverage tax on retail drink sales), and vehicle rental tax. Also collects the 1% Allegheny County local sales tax that combines with the state 6% for the 7% Pittsburgh sales rate.

Allegheny County Office of Property Assessments

The county assessment authority. Office at 542 Forbes Avenue, 3rd Floor, Pittsburgh PA 15219. Administers real-property assessments across Allegheny County, the Homestead Exclusion, the Senior Citizen Tax Relief program, and the LERTA (Local Economic Revitalization Tax Assistance) abatement program. Property-tax assessment appeals run to the Allegheny County Board of Property Assessment Appeals and Review, then to the Allegheny County Court of Common Pleas Civil Division.

U.S. District Court — Western District of Pennsylvania, Pittsburgh 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 (W.D. Pa., Pittsburgh Division), located at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street, Pittsburgh PA 15219, or the U.S. Court of Federal Claims in Washington, D.C.

IRS Independent Office of Appeals

The administrative-appeals body within the IRS that resolves cases without litigation. Pittsburgh cases run through the Appeals offices serving the mid-Atlantic and Great Lakes regions. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

Taxpayer Advocate Service — Pittsburgh

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

Allegheny County Department of Real Estate (Recorder of Deeds)

The recording office for Notices of Federal Tax Lien and Pennsylvania state tax liens affecting real property in Pittsburgh, the surrounding boroughs, and the Mon Valley. Office at the Frick Building, 437 Grant Street, Third Floor, Pittsburgh PA 15219. NFTL recording on the wrong county's records fails to attach to title — a procedural defect that can be the basis of a lien-withdrawal request under Form 12277.

Speak with a tax attorney about your Pittsburgh matter

Free consultation, attorney-client privileged, no obligation. If a Notice of Deficiency, a Final Notice of Intent to Levy, or a Pennsylvania DOR Notice of Assessment is in front of you, the deadline to respond is real and short — call today.

Call (800) 883-8301 Free Consultation

Frequently asked questions — Pittsburgh tax

What is the Pittsburgh Local Earned Income Tax and how is it different from PA state tax?

The Pittsburgh Local Earned Income Tax is a 3% wage tax on residents of the City of Pittsburgh under Pittsburgh Code Title 2 Article VII Chapter 245 — 1% to the City and 2% to the Pittsburgh Public School District. Non-residents who work in Pittsburgh pay a 1% LST on wages earned in the City. This sits on top of, not in place of, the Pennsylvania state personal income tax of 3.07% under 72 Pa.C.S. § 304. A Pittsburgh resident pays roughly 6.07% combined on every wage dollar before federal tax. The LST is administered for the City by Jordan Tax Service. A separate $52 annual Local Services Tax (LST) applies to anyone who works in the City regardless of residency.

How does Pennsylvania Inheritance Tax work and who pays it?

The Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116 is paid on transfers at death from a Pennsylvania resident, or on Pennsylvania-situs real property and tangible personal property from a non-resident. Rates: 0% to a surviving spouse or a parent inheriting from a child under 21; 4.5% to lineal descendants and lineal ancestors (children, grandchildren, parents, grandparents); 12% to siblings; 15% to nieces, nephews, friends, and any other non-relative. Pennsylvania is one of only six states still imposing a separate inheritance tax. Form REV-1500 is filed with the Allegheny County Register of Wills, City-County Building Room 327, within nine months of death. A 5% discount applies to tax paid within three months. Coordination with the federal estate-tax return on Form 706 is its own engagement layer when the gross estate is large enough to trigger federal filing.

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

The U.S. Tax Court holds regular trial sessions in Pittsburgh itself at the Joseph F. Weis Jr. United States Courthouse, 700 Grant Street. Pittsburgh is the primary Western Pennsylvania trial city — a Butler, Beaver, Washington, Westmoreland, Fayette, Greene, or Lawrence County petitioner can request the Pittsburgh trial location when filing the Tax Court petition. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline from the IRS Statutory Notice of Deficiency under IRC § 6213(a) is jurisdictional — a single day late and the federal assessment becomes final.

What is the Pennsylvania Board of Finance and Revenue and what is its deadline?

The Pennsylvania Board of Finance and Revenue is the state's administrative tax-appeals tribunal, seated at 1101 South Front Street, Suite 400, Harrisburg. It hears second-level appeals from final decisions of the PA Department of Revenue Board of Appeals on personal income tax, corporate net income tax, sales and use tax, employer withholding, and inheritance tax. The petition deadline is 60 days from the Board of Appeals decision under 72 Pa.C.S. § 9702 — tighter than the federal 90-day Tax Court deadline. Decisions are appealable to the Pennsylvania Commonwealth Court within 30 days under 42 Pa.C.S. § 763. Victory Tax Lawyers handles the administrative track through the Board of Appeals and the Board of Finance and Revenue under PA Form REV-677; we refer Commonwealth Court litigation to locally admitted Pennsylvania counsel.

I am a UPMC physician with side 1099 income — what should I expect?

UPMC attending physicians, surgical specialists, and clinical-faculty members frequently carry side 1099 income from independent surgical centers, second-opinion telemedicine, pharmaceutical clinical-trial honoraria, expert-witness work, and royalty arrangements on medical devices or patents. The 1099 income is reported on Schedule C and subject to 15.3% SECA self-employment tax under IRC § 1401 in addition to ordinary income tax at the 32% to 37% federal marginal rate, plus 3.07% Pennsylvania and 3% Pittsburgh resident LST. Without quarterly Form 1040-ES payments under IRC § 6654 and PA Form REV-414 estimates, a strong 1099 year produces a five- or six-figure balance the following April. Resolution paths include partial-pay Installment Agreements, S-corporation restructuring to control SECA, and reasonable-compensation analysis if the 1099 work is run through an LLC or PC.

What is Pennsylvania's collection statute of limitations?

72 Pa.C.S. § 346 gives the PA DOR three years from a return's due date to assess Pennsylvania personal income tax (extended for substantial omissions, with no limit for fraud or unfiled returns). Once an assessment is final, the DOR records a state tax lien under 72 Pa.C.S. § 7805 in the Prothonotary's office for the county where the taxpayer holds real property. The lien remains effective until satisfied and may be renewed by re-recording. The federal CSED under IRC § 6502 is a separate ten-year clock running from the federal assessment date. Coordinated case planning hinges on knowing both clocks before any action that could restart either one.

Can I be audited by both the IRS and the Pennsylvania DOR for the same year?

Yes. The IRS and the Pennsylvania Department of Revenue operate independently and share information through the IRS-state exchange program. A federal audit adjustment is routinely reported to Pennsylvania under the state's federal-change reporting rule (72 Pa.C.S. § 7330(b)), and vice versa. We coordinate the two audits to prevent inconsistent positions on the federal record from costing you on the Pennsylvania return — and on the Pittsburgh Local Earned Income Tax return administered by Jordan Tax Service for the City of Pittsburgh and the Pittsburgh Public School District.

Does Pennsylvania have an Offer in Compromise equivalent to the federal program?

Yes, but it is narrower than the federal program. The Pennsylvania Department of Revenue operates a Compromise program under 72 Pa.C.S. § 9707 for personal income tax, corporate net income tax, sales and use tax, and other Pennsylvania taxes. The DOR considers compromises based on doubt as to collectibility or doubt as to liability — the third federal ground, effective tax administration, has no Pennsylvania analog. The PA DOR also operates a Deferred Payment Plan program for taxpayers who cannot pay in full but can pay over time. All Pennsylvania returns must be filed before consideration, and current-year compliance is verified. We typically run a state Compromise in parallel with the federal Offer where both debts are real.

I work at Carnegie Mellon or Pitt and have a spin-out startup — how does § 1202 QSBS apply?

IRC § 1202 excludes from federal gross income up to the greater of $10 million or 10x basis on the sale of qualified small business stock held for more than five years from original issuance. The five-year clock starts on the date the stock is acquired from the corporation in exchange for cash, property, or services — not on a § 83(b) election or vest date. Carnegie Mellon Robotics Institute spin-outs, Pitt biotech and bioengineering startups, and AI-research commercialization vehicles that issued founder shares while the company had under $50 million in gross assets and engaged in a qualified active trade or business may qualify. Pennsylvania does not have a state-level § 1202 conformity provision — the state taxes the gain at the flat 3.07% rate on Schedule D of PA-40. Documentation of the issuance date, original asset test, and basis is the single most valuable thing a founder can keep on file.

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

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 Pittsburgh. For Pennsylvania DOR administrative work, we file PA Form REV-677 Power of Attorney and handle the matter remotely through the Board of Appeals and the Board of Finance and Revenue. For formal litigation in the Pennsylvania Commonwealth Court or the Pennsylvania Supreme Court, we co-counsel with locally admitted Pennsylvania attorneys. Most engagements — audit defense, OIC, IA, levy release, Tax Court — are federal and stay entirely with our firm.

What if I have unfiled returns going back several years?

The IRS Voluntary Filing Compliance policy and IRM 5.1.11.6 generally require the last six years of returns to bring a taxpayer back into compliance. Filing prior-year returns is the first step before any OIC, IA, or CNC request — IRC § 7122(d) compliance is a prerequisite for a federal Offer. Refunds claimed on returns filed more than three years after the original due date are time-barred under IRC § 6511(b)(2). Pennsylvania follows a parallel filing-compliance posture; the DOR may assess based on federal-change reporting or estimate tax when a taxpayer fails to file. Pittsburgh Local Earned Income Tax compliance with Jordan Tax Service is a separate filing track for residents and non-resident workers.

Can the IRS levy my Pittsburgh bank account or wages?

Yes — after a Final Notice of Intent to Levy (CP90 or LT11) and expiration of the 30-day Collection Due Process window under IRC § 6330, the IRS may levy bank accounts at PNC Bank, First National Bank of Pennsylvania, Dollar Bank, Citizens, S&T Bank, Northwest Bank, or any Pennsylvania-chartered institution and serve wage levies on Pittsburgh employers including UPMC, PNC, Highmark Health, BNY Mellon, Duolingo, U.S. Steel, ATI, Arconic, Heinz, Dick's Sporting Goods, FedEx Ground, Carnegie Mellon, and the University of Pittsburgh. A timely Form 12153 CDP request halts collection while the case is reviewed by Appeals. After a CDP determination, the taxpayer has 30 days to petition the U.S. Tax Court under IRC § 6330(d)(1). Pennsylvania issues parallel state tax liens under 72 Pa.C.S. § 7805 recorded in the Allegheny County Prothonotary's office.

I work at Duolingo or a CMU spin-out and have RSUs — why did I owe so much tax this year?

RSU vest events are taxed as W-2 ordinary income at the supplemental wage withholding rate, which is currently 22% federal on amounts up to $1 million per year (37% above). If your actual marginal federal rate is 32%, 35%, or 37%, you are underwithheld by 10 to 15 percentage points on every vest. Add 3.07% Pennsylvania plus the 3% Pittsburgh resident Local Earned Income Tax, and a single year of vesting can produce a $50,000 to $300,000+ balance due. The fix is W-4 adjustment plus quarterly Form 1040-ES under IRC § 6654 and Pennsylvania Form REV-414 estimates. Duolingo, Aurora Innovation, Astrobotic, and post-IPO CMU and Pitt spin-out equity-holders see this pattern every vest cycle.

A family member died in Pennsylvania — do I owe state inheritance tax?

Possibly yes. The Pennsylvania Inheritance Tax under 72 Pa.C.S. § 9116 has no exemption for non-spouse heirs — the tax applies from the first dollar. Rates are 0% to a surviving spouse, 4.5% to lineal descendants and ancestors (children, grandchildren, parents, grandparents), 12% to siblings, and 15% to nieces, nephews, and non-relatives. Pennsylvania is one of only six states still imposing a separate inheritance tax. A Squirrel Hill, Shadyside, Fox Chapel, Sewickley, or Mt. Lebanon home plus retirement accounts and life-insurance proceeds payable to the estate can produce a meaningful inheritance-tax bill even for a child inheriting from a parent. Form REV-1500 is due nine months from death and is filed with the Allegheny County Register of Wills at the City-County Building, Room 327. A 5% discount applies to tax paid within three months. Coordination with the federal Form 706 estate-tax return is its own engagement layer.

How long does a federal Offer in Compromise take to process?

An IRS Offer in Compromise typically takes six to twelve months from filing to a final decision. The IRS deems an Offer accepted if not rejected within 24 months under IRC § 7122(f). While the OIC is pending, IRC § 6331(k) bars most levies, and the CSED is tolled. Rejected offers carry a 30-day Appeals window. A well-documented Offer with a complete Form 433-A(OIC) or 433-B(OIC) financial package moves faster than one returned for incompleteness. A Pennsylvania Compromise petition under 72 Pa.C.S. § 9707 typically runs four to nine months on a parallel track.

Will hiring a tax attorney stop IRS collection action immediately?

Once Form 2848 is on file, the IRS routes all communication through the attorney and stops contacting the taxpayer directly. Active levies are not automatically lifted by the POA filing alone — release requires either a financial showing under IRC § 6343, a CDP filing under IRC § 6330, or an installment-agreement or OIC submission that triggers the IRC § 6331(k) collection bar. We move on those concurrently when a levy is in place. Pennsylvania state collection follows a similar pattern: a PA Form REV-677 routes DOR contact, and a pending Pennsylvania Compromise petition pauses state tax-lien enforcement.

About the author

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

Page last reviewed: May 25, 2026. Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Pennsylvania statute citation references the Pennsylvania Consolidated Statutes Title 72. 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 Pennsylvania Department of Revenue, the U.S. Tax Court, the Pennsylvania Board of Finance and Revenue, the Pennsylvania Commonwealth 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 Commonwealth of Pennsylvania; where a Pennsylvania state-court appearance or Pennsylvania Commonwealth Court tax 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.

Authorities cited on this page

26 U.S.C. § 7122 — Federal Offer in Compromise
26 U.S.C. § 6159 — Installment Agreements
26 U.S.C. § 6321 — Federal Tax Lien
26 U.S.C. § 6325 — Lien Release and Discharge
26 U.S.C. § 6331 — Levy and Distraint
26 U.S.C. § 6343 — Release of Levy
26 U.S.C. § 6502 — Collection Statute Expiration
26 U.S.C. § 6213 — Tax Court Petition Window
26 U.S.C. § 6320 — CDP for Liens
26 U.S.C. § 6330 — CDP for Levies
26 U.S.C. § 6651 — Failure-to-File and Failure-to-Pay
26 U.S.C. § 6672 — Trust Fund Recovery Penalty
26 U.S.C. § 6015 — Innocent Spouse Relief
26 U.S.C. § 7345 — Passport Revocation
26 U.S.C. § 1202 — Qualified Small Business Stock
26 U.S.C. § 1061 — Carried-Interest Holding Period
26 U.S.C. § 174 — R&D Capitalization
26 U.S.C. § 83 — Property Transferred for Services / 83(b) Election
26 U.S.C. § 1401 — Self-Employment Tax
72 Pa.C.S. § 304 — Pennsylvania 3.07% personal income tax
72 Pa.C.S. § 346 — Pennsylvania assessment statute of limitations
72 Pa.C.S. § 352 — Pennsylvania failure-to-file penalty
72 Pa.C.S. § 353 — Pennsylvania underpayment penalty
72 Pa.C.S. § 7202 — Pennsylvania sales and use tax
72 Pa.C.S. § 7240 — Pennsylvania responsible-person liability
72 Pa.C.S. § 7330 — Pennsylvania federal-change reporting
72 Pa.C.S. § 7401 — Pennsylvania corporate net income tax
72 Pa.C.S. § 7805 — Pennsylvania state tax lien
72 Pa.C.S. § 9116 — Pennsylvania Inheritance Tax
72 Pa.C.S. § 9702 — PA Board of Finance and Revenue petition deadline
72 Pa.C.S. § 9707 — Pennsylvania Compromise program
42 Pa.C.S. § 763 — Pennsylvania Commonwealth Court tax jurisdiction
Pittsburgh Code Title 2 Article VII Ch 245 — Pittsburgh Local Earned Income Tax