Tax Attorney in Portsmouth, VA
Federal IRS representation for Portsmouth residents, Norfolk Naval Shipyard civilian DOD shipbuilders carrying Q clearances and naval-reactor-class clearances, Naval Medical Center Portsmouth physicians and 1099 locum providers, Jefferson Lab (Thomas Jefferson National Accelerator Facility) DOE physicists in nearby Newport News, New Port and Elizabeth River maritime operators, Filipino-American and African-American Navy families with overseas accounts, Olde Towne and Park View small-business owners, and Portsmouth working households navigating EITC eligibility under IRC § 32 — audits, back taxes, liens, levies, Offers in Compromise filings, and U.S. Tax Court petitions tried five miles across the Elizabeth River at 600 Granby Street, Norfolk. Portsmouth is an independent city under Virginia’s unique city-county structure, with no overlapping county government. Virginia Department of Taxation matters are handled remotely through Form PAR 101 Power of Attorney filed alongside IRS Form 2848.
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Portsmouth taxpayers facing IRS collection or Virginia Department of Taxation action — the clock is short
An IRS CP504 or LT11 starts a 30-day clock under IRC § 6330 to file a Collection Due Process petition before the federal government can levy a Norfolk Naval Shipyard civilian-employee paycheck, a Naval Medical Center Portsmouth W-2, a Jefferson Lab Thomas Jefferson National Accelerator Facility federal contractor payroll feed, a Navy Federal Credit Union or Truist account, or any Portsmouth employer wage stream. A Statutory Notice of Deficiency starts a separate 90-day clock under IRC § 6213(a) to petition the U.S. Tax Court, with trial sessions calendared five miles across the Elizabeth River at the Walter E. Hoffman U.S. Courthouse at 600 Granby Street in Norfolk — the same building that houses the U.S. District Court for the Eastern District of Virginia, Norfolk Division, for federal-tax refund suits under IRC § 7422.
Virginia operates a graduated personal income tax topping out at 5.75% under Va. Code § 58.1-320 and a 6% corporate income tax under Va. Code § 58.1-400. The Virginia Department of Taxation runs an administrative appeals track through the Office of Tax Commissioner under Va. Code § 58.1-1821, with judicial review available in the Portsmouth Circuit Court under Va. Code § 58.1-1825. We pull federal account transcripts on Form 8821, file Form 2848 with the IRS and Form PAR 101 with the Virginia Department of Taxation, calculate every Collection Statute Expiration Date, and where state and federal exposures overlap, run the two tracks in parallel from our Los Angeles office.
$100M+
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states served via Form 2848
Federal tax representation for Portsmouth taxpayers
Victory Tax Lawyers, LLP is a California-Bar-admitted tax-resolution law firm headquartered 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 trial court of nationwide jurisdiction — calendars cases for Hampton Roads taxpayers across the Elizabeth River in downtown Norfolk at 600 Granby Street, five miles from Olde Towne Portsmouth. From our Robertson Boulevard office, we represent Portsmouth residents and Portsmouth-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.
Federal tax practice is governed by Treasury under 31 CFR Part 10 (Circular 230). An attorney in good standing with any state bar may represent a taxpayer before the IRS in any state through Form 2848. The U.S. Tax Court is a federal court with national jurisdiction; admission to that court is national, not state-bound. For most Portsmouth engagements, no Virginia State Bar admission is required at any stage of the case — the work is federal from start to finish.
For Virginia state-tax matters — Virginia Department of Taxation income-tax assessments, sales-and-use tax disputes, pass-through entity tax filings, or administrative appeals before the Office of Tax Commissioner — we file Form PAR 101 (Virginia Tax Power of Attorney) and handle the matter remotely from Los Angeles. Where a Virginia state-court appearance is required — a Portsmouth Circuit Court judicial-review action on a Tax Commissioner final determination under Va. Code § 58.1-1825, for example, or a Virginia Supreme Court appeal — we associate with locally admitted Virginia counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure, stays with us.
Portsmouth carries a tax profile shaped above all by Norfolk Naval Shipyard. Founded in 1767 on the Elizabeth River’s Portsmouth bank, the shipyard is the oldest continuously operating naval shipyard in the United States and the federal government’s largest civilian shipbuilding facility on the East Coast. Thousands of Portsmouth residents work there as civilian Department of Defense employees holding Secret, Top Secret, Q (Department of Energy nuclear), and naval-reactor-class clearances tied to aircraft carrier and submarine refit, refueling, and inactivation. Add Naval Medical Center Portsmouth (the largest Navy hospital on the East Coast), Jefferson Lab (the Thomas Jefferson National Accelerator Facility in nearby Newport News, a DOE physics research center), the New Port maritime logistics chain along the Elizabeth River, a long-established Filipino-American Navy population, a deep African-American community with EITC-eligibility patterns under IRC § 32, and Olde Towne and High Street small-business operators — and the federal-tax case mix in Portsmouth looks distinct from any inland Virginia city. Every Portsmouth engagement we accept is framed against those facts.
Your tax rights as a Portsmouth taxpayer
Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights come from Title 58.1 of the Code of Virginia and the Virginia Department of Taxation’s published guidance, including the Taxpayer Bill of Rights at tax.virginia.gov. Knowing both sides is the difference between a clean resolution and a missed deadline that ends in a Navy Federal Credit Union levy or a Virginia Department of Taxation memorandum of lien recorded at the Portsmouth Circuit Court Clerk’s Office.
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 with the IRS Centralized Authorization File, the IRS must direct all contact to the attorney first. The Virginia Department of Taxation honors a parallel POA through Form PAR 101 for state-tax matters.
Right to 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 assessed tax first. Miss the 90-day window and the deficiency becomes final. The Tax Court calendars Hampton Roads cases at the Walter E. Hoffman U.S. Courthouse, 600 Granby Street in Norfolk, about five miles from Olde Towne Portsmouth across the Downtown Tunnel.
Collection Due Process
IRC § 6320 (lien) and IRC § 6330 (levy) give you a 30-day window to request a CDP hearing on Form 12153 once the IRS files a Notice of Federal Tax Lien with the Portsmouth Circuit Court Clerk or issues a Final Notice of Intent to Levy. A timely CDP request halts collection and preserves judicial review in the U.S. Tax Court.
Right to Virginia administrative appeal
Va. Code § 58.1-1821 allows an administrative appeal to the Virginia Tax Commissioner within 90 days of a notice of assessment. The Tax Commissioner issues a written final determination; judicial review of that determination is filed in a Virginia Circuit Court — typically the Portsmouth Circuit Court for Portsmouth taxpayers — under Va. Code § 58.1-1825 within three years of the assessment date.
Right to relief from federal penalties
First-Time Abate administrative relief under IRM 20.1.1.3.6 removes a single year of failure-to-file or failure-to-pay penalties under IRC § 6651 for taxpayers with a clean three-year compliance history. Reasonable-cause abatement reaches further when supported by documentation — serious illness, hurricane disruption under IRC § 7508A, military deployment under IRC § 7508, or reliance on competent advice.
Right to recover fees
IRC § 7430 allows recovery of administrative and litigation costs where the IRS takes a position not substantially justified and the taxpayer prevails. The threshold is real and used most often in audit-reconsideration and Innocent Spouse cases under IRC § 6015 where the Service’s posture cannot be defended on the record.
How Victory Tax Lawyers helps Portsmouth 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 under IRM 5.8.4, and pursue doubt-as-to-collectibility offers where collection in full is not feasible within the remaining CSED. The federal $205 application fee may be waived for low-income certified offers — a waiver that fits the EITC-eligibility profile of many Portsmouth working households under IRC § 32. On the Virginia side, the Department of Taxation may compromise state liabilities under Va. Code § 58.1-105 where doubt as to liability or collectibility exists; we file Form OIC B-3 alongside the federal package when state debt is part of the picture.
Installment Agreements under IRC § 6159
Streamlined IAs (under $50,000), partial-pay IAs under IRC § 6159(d), and full-pay agreements. Partial-pay structures matter most where IRC § 6502 will extinguish the balance before payoff — an under-used resolution path for Portsmouth taxpayers carrying $50,000 to $250,000 in federal debt with a CSED running before full payment is realistic. For Norfolk Naval Shipyard civilian employees holding active Q or naval-reactor-class clearances, the timing and documentation of an Installment Agreement also feed directly into SF-86 reinvestigation paperwork. Virginia state payment plans run separately through the Department of Taxation under Va. Code § 58.1-1813.
Lien discharge, subordination, and withdrawal
When a Notice of Federal Tax Lien filed with the Portsmouth Circuit Court Clerk blocks a property sale or refinance in Olde Towne, Port Norfolk, Park View, Cradock, Churchland, Cavalier Manor, Westhaven, or any Portsmouth address, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). The IRS procedures sit in IRC § 6325 and IRM 5.12; the timing must align with the closing date set by the title company. Virginia Department of Taxation memoranda of lien are recorded at the same Circuit Court Clerk’s Office and require separate state-side release procedures.
Levy release under IRC § 6343
Wage levies on the Norfolk Naval Shipyard civilian-employee payroll feed, Naval Medical Center Portsmouth staff, Bon Secours Maryview Medical Center, the City of Portsmouth, Portsmouth Public Schools, Jefferson Lab (Thomas Jefferson National Accelerator Facility) contractors, and other Hampton Roads employers; bank levies on Navy Federal Credit Union, Towne Bank, Truist, Atlantic Union Bank, and Wells Fargo. For Norfolk Naval Shipyard civilian DOD employees, the federal payroll stream runs through the Defense Finance and Accounting Service Indianapolis Civilian Pay Office and is leviable on the same procedural posture as private-sector wages. 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 the IRS Independent Office of Appeals.
Audit defense and U.S. Tax Court litigation
Correspondence audits, office audits, and field examinations — including sensitive issues like FBAR FinCEN Form 114 for Philippine peso and other overseas accounts held by Filipino-American Navy families, classified research expenditures under IRC § 174 for Jefferson Lab DOE physicists, post-doctoral fellowship reporting under IRC § 117(c) for Jefferson Lab and Old Dominion University researchers, Naval Medical Center Portsmouth 1099 locum-tenens physician self-employment-tax exposure, Norfolk Naval Shipyard contractor W-2 versus 1099 misclassification, EITC eligibility audits under IRC § 32 for Portsmouth working households, and hurricane casualty-loss claims under IRC § 165(h) and involuntary-conversion deferrals under IRC § 1033. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window for trial at 600 Granby Street in Norfolk.
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. For accuracy-related penalties under IRC § 6662, we document substantial authority or adequate disclosure to defeat the assessment. Combat-zone deployment under IRC § 7508 supports automatic abatement of late-filing and late-payment penalties for Portsmouth-based Navy reservists and contractors deployed in support of Atlantic Fleet operations. Hurricane Helene 2024, Hurricane Matthew 2016, Hurricane Isabel 2003, and earlier-storm deadline postponements under IRC § 7508A apply to Portsmouth taxpayers within designated FEMA disaster areas.
Twelve types of Portsmouth tax matters we handle
Federal-tax cases for Portsmouth residents and businesses, framed against the city’s Norfolk Naval Shipyard civilian shipbuilding workforce, Navy medicine, Jefferson Lab DOE research, maritime logistics, Filipino-American Navy heritage, and African-American working-class population profile.
Norfolk Naval Shipyard civilian DOD shipbuilders
Founded in 1767 on the Portsmouth bank of the Elizabeth River, Norfolk Naval Shipyard is the oldest U.S. naval shipyard and the federal government’s flagship civilian shipbuilding facility on the East Coast. Thousands of Portsmouth residents draw federal civilian W-2s tied to carrier refit, submarine overhaul, and nuclear-reactor refueling. Many hold Secret, Top Secret, Q (DOE nuclear), and naval-reactor-class clearances. Unresolved tax debt, FBAR non-compliance, and unfiled returns each trigger SF-86 adverse information reportable to the Department of Energy, Naval Reactors, and the Defense Counterintelligence and Security Agency. We coordinate resolution with that clearance reality in view.
Naval Medical Center Portsmouth 1099 physicians
Naval Medical Center Portsmouth, the largest Navy hospital on the East Coast, produces substantial 1099 contractor work for anesthesiologists, radiologists, emergency-medicine groups, hospitalists, CRNAs, and locum-tenens physicians supplementing the active-duty Navy medical corps. Schedule C reporting, self-employment tax under IRC § 1401, and quarterly estimated-tax compliance under IRC § 6654 are recurring audit issues. TRICARE network providers serving the Naval Medical Center Portsmouth catchment area also produce coordinated W-2/1099 mixes.
Jefferson Lab DOE physicists and researchers
The Thomas Jefferson National Accelerator Facility in nearby Newport News — commonly known as Jefferson Lab — is a U.S. Department of Energy national laboratory operated under DOE contract for nuclear-physics research. Many Portsmouth residents commute there for staff-scientist and contractor positions. Classified research-and-experimental expenditures under IRC § 174 (capitalized and amortized post-TCJA), Q-clearance compliance, post-doctoral fellowship reporting under IRC § 117(c), and foreign-collaborator tax treaty positions under IRC § 894 produce recurring engagements.
EITC eligibility under IRC § 32
Portsmouth carries a working-household population — including a deep-rooted African-American community — where median income sits below the Hampton Roads metro average and Earned Income Tax Credit eligibility is a real, recurring tax benefit. IRC § 32 EITC audits, two-year and ten-year IRC § 32(k) bans following claimed-in-error determinations, and recapture exposure on disallowed prior-year credits are common engagements. Properly documented EITC claims for qualifying children with valid Social Security numbers under IRC § 32(c)(3)(D) survive examination; sloppy ones do not.
FBAR for Filipino-American Navy families
Hampton Roads hosts a long-established Filipino-American Navy population tied to wartime Filipino enlistment in the U.S. Navy — first as stewards’ mates, later across the full service — with Portsmouth carrying its share of multi-generational Filipino-American families. Joint family accounts in Manila, Cebu, Iloilo, Davao, and Bacolod are common, and FinCEN Form 114 (FBAR) is required when aggregate balances exceed $10,000 at any point during the year. Streamlined Filing Compliance Procedures are the standard non-willful disclosure path.
ITIN and ITIN-renewal filings
Portsmouth’s growing Hispanic community — concentrated in Cradock, Cavalier Manor, and Park View — produces recurring Individual Taxpayer Identification Number engagements under IRC § 6109. ITINs filed on Form W-7 with a Certifying Acceptance Agent, ITIN renewals when prior credentials expire under the Protecting Americans from Tax Hikes Act schedule, and W-7 documentation packaging for spouses and dependents claimed on Schedule 8812 are routine engagements alongside FBAR and Streamlined Filing matters.
Trust Fund Recovery Penalty
IRC § 6672 imposes 100% personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. Olde Towne restaurant operators along High Street and Crawford Street, Portsmouth Marina hospitality LLCs, construction contractors working Cradock and Churchland infill projects, small shipyard-support vendors with federal subcontracting work, and minority-owned small businesses in Park View are the most common targets, with the IRS Form 4180 interview as the qualification mechanism.
Norfolk Naval Shipyard contractor 1099 vs W-2
Federal shipyard-support contracts run thousands of subcontractor relationships across BAE Systems, HII, and smaller mom-and-pop shipfitters, welders, electricians, and pipefitters supporting Norfolk Naval Shipyard refit work. Worker-classification disputes under Treas. Reg. § 31.3121(d)-1, IRS Section 530 safe-harbor defenses, Form SS-8 determinations, and back-withholding liability under IRC § 3402(d) recur. CP2000 mismatches on 1099-NEC reporting follow when a subcontractor underreports.
Servicemembers Civil Relief Act (SCRA) tolling
SCRA, 50 U.S.C. § 3991, tolls IRS collection limitation periods during periods of active military service plus 180 days. For Portsmouth-based Navy reservists, contracted shipyard riders embarking on sea trials, and active-duty members assigned to ships in Norfolk Naval Shipyard refit who maintain Portsmouth residence, this changes the CSED math on every assessed year — both extending taxpayer rights and complicating collection planning across back-to-back tours.
Hurricane casualty losses
Hurricane Helene 2024, Hurricane Florence 2018, Hurricane Matthew 2016, Hurricane Isabel 2003, and earlier storms produced FEMA disaster declarations covering the City of Portsmouth. Personal casualty losses under IRC § 165(h)(5) are limited to federally declared disaster areas post-TCJA; involuntary-conversion deferrals under IRC § 1033 apply to insurance reimbursements on Port Norfolk and Olde Towne flood loss; IRC § 7508A postpones filing and payment deadlines for designated disaster periods. Elizabeth River tidal flooding produces recurring casualty exposure on waterfront parcels.
Passport revocation under IRC § 7345
A seriously delinquent tax debt (the indexed threshold is $62,000 for 2025) triggers State Department certification and passport hold. For Portsmouth’s Norfolk Naval Shipyard civilian DOD workers, Jefferson Lab researchers traveling for international physics collaborations, Filipino-American families with international travel needs, and Naval Medical Center Portsmouth contractors, passport access is operationally required, making IRC § 7345(e) reversal a frequent priority engagement.
Innocent Spouse relief under IRC § 6015
A jointly-filed return tied to a now-former spouse’s understatement leaves both parties liable until Innocent Spouse relief is granted on Form 8857. Traditional relief under IRC § 6015(b), separation-of-liability relief under § 6015(c), and equitable relief under § 6015(f) each carry distinct factual tests. Portsmouth Juvenile and Domestic Relations District Court and Portsmouth Circuit Court divorce decrees do not bind the IRS — the Service applies its own equitable factors under Rev. Proc. 2013-34.
Nine common causes of tax debt for Portsmouth taxpayers
Patterns we see repeatedly across Portsmouth cases. None of them are unusual — all of them are resolvable.
1. EITC disallowance and recapture
A Portsmouth working household claims the Earned Income Tax Credit under IRC § 32, the IRS examines the return, and a residency or relationship test fails on the qualifying-child documentation. The credit is recaptured and a two-year ban under § 32(k)(1)(B)(ii) attaches. Reconstruction of school records, lease documents, and benefits enrollment files defeats the ban and restores the credit.
2. Norfolk Naval Shipyard payroll levy exposure
A civilian shipyard employee with multi-year back balances faces a Final Notice of Intent to Levy on the federal payroll feed processed through DFAS Indianapolis Civilian Pay. Beyond cash impact, the levy is itself an SF-86 reportable event affecting Q-clearance and naval-reactor-class clearance posture for ongoing reactor and submarine work.
3. Jefferson Lab fellowship undertaxation
A post-doctoral researcher at the Thomas Jefferson National Accelerator Facility treats a research fellowship as fully excludable under IRC § 117, only to discover that the portion requiring services rendered is taxable wages under IRC § 117(c). A CP2000 follows. Reconstruction of the appointment letter terms determines the split.
4. Olde Towne small-business undercollection
A High Street, Crawford Street, or Portsmouth Marina restaurant or boutique under-collects the 6% combined Virginia sales tax (4.3% state + 1% Portsmouth + 0.7% Hampton Roads regional) for two quarters. The Virginia Department of Taxation issues a sales-tax assessment with Va. Code § 58.1-1813 officer-liability tail riding behind it.
5. Business closure with unpaid Form 941
A Portsmouth LLC or S-corp closes with unpaid Form 941 payroll-tax balances. IRC § 6672 follows the responsible officer personally for the trust-fund portion long after the entity is dissolved, and Va. Code § 58.1-1813 imposes parallel state employer-withholding officer liability.
6. Naval Medical Center locum undertaxation
A Naval Medical Center Portsmouth-affiliated physician or CRNA takes locum-tenens 1099 work without making quarterly Form 1040-ES payments and faces self-employment tax under IRC § 1401 plus Virginia estimated-tax shortfall plus accuracy-related penalty exposure under IRC § 6662. Anesthesia and emergency-medicine moonlighting through Hampton Roads staffing agencies produces the same pattern.
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. IRM 5.1.11.6 generally requires the last six years filed to bring a taxpayer back into compliance. Virginia’s parallel limitation under Va. Code § 58.1-1812 is six years.
8. Real-estate sale without estimated tax
An Olde Towne historic-district, Port Norfolk waterfront, or Churchland residential sale generating substantial capital gain with no Form 1040-ES payment produces a tax bill the next April. The IRC § 121 personal-residence exclusion ($250,000/$500,000) helps but does not always eliminate exposure for second homes and investment properties.
9. Unreported overseas family accounts
A Filipino-American Portsmouth family inherits or jointly holds bank accounts in Manila, Cebu, or Iloilo. Aggregate balances cross $10,000 and FBAR obligations under 31 U.S.C. § 5314 are triggered. Streamlined Filing Compliance Procedures are the standard non-willful disclosure path; willful exposure under 31 U.S.C. § 5321(a)(5) is materially different.
Eight tax liabilities that pull in Portsmouth taxpayers
Federal authority alongside the Virginia statute where there is a parallel. Where the parallel exists, both exposures must be worked simultaneously.
Failure to file federal return
IRC § 6651(a)(1) imposes 5% per month, max 25%, plus interest under IRC § 6601. Failure-to-pay under § 6651(a)(2) adds 0.5% per month up to a separate 25% cap. Combat-zone deployment under IRC § 7508 supports automatic abatement for the deployment period.
Failure to file Virginia income tax
Va. Code § 58.1-347 imposes a Virginia late-filing penalty of 6% per month (capped at 30%) on the tax due, with statutory interest accruing separately. The Virginia Department of Taxation may also impose the § 58.1-308 substitute-return process when no return is filed after notice.
Federal § 7122 Offer in Compromise eligibility
All federal returns must be filed (IRC § 7122(d) compliance) and the offer must reflect Reasonable Collection Potential under IRM 5.8.4. The non-refundable $205 application fee may be waived for low-income certified offers — a waiver that frequently applies to Portsmouth EITC-eligible households. Virginia state OICs under Va. Code § 58.1-105 follow a separate Form OIC B-3 process.
Virginia sales-and-use tax
Va. Code Title 58.1, Chapter 6 imposes a 4.3% state sales tax plus 1% Portsmouth local option plus 0.7% Hampton Roads regional transportation rate — a combined 6% rate. The 6% rate applies to High Street, Crawford Street, and Portsmouth Marina hospitality and retail sales. Officer liability for unpaid trust-fund sales tax reaches under Va. Code § 58.1-1813.
Trust Fund Recovery Penalty
IRC § 6672 imposes 100% personal liability on responsible persons for unpaid federal trust-fund employment tax. Va. Code § 58.1-1813 imposes a parallel state-side personal-liability tail on responsible officers for unpaid Virginia withholding and sales tax held in trust for the Commonwealth.
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. Virginia parallels this through § 58.1-308 substitute-return understatement penalties.
Virginia Pass-Through Entity Tax (PTET)
Va. Code § 58.1-390.3 allows qualifying pass-through entities to elect to pay Virginia income tax at the entity level, sidestepping the IRC § 164(b)(6) federal SALT cap for owners. Late or defective PTET elections produce double-tax exposure that is typically resolvable through amended returns and Form 502PTET refiles.
Willful failure to collect or pay over tax
IRC § 7202 makes willful failure to collect, account for, or pay over withheld tax a felony — an exposure that recurs in Portsmouth hospitality-LLC employment-tax cases and small shipyard-vendor situations where pay-over is skipped to keep the lights on. Criminal referral risk runs alongside the civil Trust Fund Recovery Penalty under IRC § 6672.
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 IRS national acceptance rate sits around 33%; preparation determines the outcome more than any other factor. Past results do not guarantee future outcomes — each case turns on its facts.
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 — particularly relevant for IRC § 7508 combat-zone deployments and IRC § 7508A hurricane disaster postponements.
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 at the Portsmouth Circuit Court Clerk.
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 Virginia Department of Taxation.
Why Victory Tax Lawyers for a Portsmouth federal-tax case
Victory Tax Lawyers is California-Bar-admitted, not Virginia State 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 in any of its trial locations, including the Norfolk session calendared at the Walter E. Hoffman U.S. Courthouse on Granby Street, five miles from Olde Towne Portsmouth. 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 Portsmouth clients never need a separately admitted Virginia attorney because the case is, at its core, federal.
When a matter does require Virginia state-court appearance — a Portsmouth Circuit Court judicial-review action under Va. Code § 58.1-1825 on a Tax Commissioner final determination, a Virginia Court of Appeals tax appeal, or a Supreme Court of Virginia review — we associate with locally admitted Virginia counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the bigger exposure, stays with us. Virginia Department of Taxation administrative work runs remotely through Form PAR 101 without requiring Virginia State Bar admission.
The engagement is 100% remote. Documents move through a secure client portal; consultations happen by phone or video; signatures are handled electronically. A Portsmouth client never drives anywhere — not to Los Angeles, not through the Downtown or Midtown Tunnel, not to the IRS Taxpayer Assistance Center at 200 Granby Street, Suite 605 in the MacArthur Federal Building across the Elizabeth River in Norfolk unless an in-person meeting is something the client wants. Federal procedures are uniform nationwide; the city in which the lawyer sits has little practical bearing on the outcome.
What distinguishes the 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 Virginia-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any Portsmouth taxpayer, at the same standard applied to a Los Angeles client.
Our seven-step process for Portsmouth 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 PAR 101
We file the federal Power of Attorney with the IRS Centralized Authorization File and Virginia Form PAR 101 with the Department of Taxation, then step in as the contact of record for both agencies.
Transcript and CSED analysis
We pull IRS account transcripts via Form 8821, calculate each year’s CSED under IRC § 6502, account for SCRA tolling where Navy reserve or active service applies, and identify other tolling events.
Strategy memo
A written summary: the resolution path (OIC, IA, CNC, audit response, CDP, Tax Court petition), the timeline, the realistic outcome range, and the federal/Virginia coordination if applicable.
Filing and negotiation
We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, Tax Court Petition, Va. § 58.1-1821 administrative appeal — and handle every IRS and Virginia Tax contact directly through the secure portal.
Compliance monitoring
After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, and prevent default that would reinstate the original balance.
Two collection clocks: federal CSED and Virginia state limitations
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, when the taxpayer is outside the United States for six months or more, and — for active-duty service members — during the period of service plus 180 days under SCRA, 50 U.S.C. § 3991.
Virginia’s parallel limitation periods are different. Under Va. Code § 58.1-1802.1, the Department of Taxation generally has seven years from the date of assessment to collect, with extensions for waivers, bankruptcy, and active military service. Va. Code § 58.1-1812 caps the assessment period for unfiled or fraudulent returns; Va. Code § 58.1-104 sets the standard three-year statute on filed returns. The interplay of two limitation periods on overlapping years is the calculation we run on every Portsmouth engagement with both federal and Commonwealth exposure.
Portsmouth tax authorities and venues
A working knowledge of the tribunals, agencies, and field offices serving Portsmouth is what separates an answered Notice from a wage levy. Below is the working list our firm uses on every Portsmouth matter. Portsmouth is an independent city — one of 38 in the Commonwealth — with no overlapping county government, so the city and the local taxing authority are one and the same.
Internal Revenue Service — Norfolk TAC
The federal tax authority, at irs.gov. The nearest Taxpayer Assistance Center to Portsmouth sits in downtown Norfolk at 200 Granby Street, Suite 605, in the MacArthur Federal Building, Norfolk, VA 23510 — about five miles east across the Elizabeth River. Appointments are required and can be scheduled through the IRS office locator or 844-545-5640.
U.S. Tax Court — Norfolk trial sessions
The United States Tax Court calendars Hampton Roads cases — Portsmouth included — for trial in Norfolk at the Walter E. Hoffman U.S. Courthouse, 600 Granby Street, Norfolk, VA 23510. A petitioner designates the preferred place of trial on the Tax Court petition under Tax Court Rule 140; Portsmouth-resident taxpayers typically designate Norfolk based on proximity. Richmond is the other Virginia trial location, about 90 miles northwest along I-64.
Virginia Department of Taxation
The Virginia state revenue authority, at tax.virginia.gov. The Department administers Virginia personal income tax under Va. Code § 58.1-320 (top rate 5.75%), corporate income tax under § 58.1-400 (6%), sales-and-use tax under Title 58.1 Chapter 6, and the Pass-Through Entity Tax under § 58.1-390.3. Headquartered at 1957 Westmoreland Street, Richmond, VA 23230, with Hampton Roads district coverage routed through the Norfolk area office. Remote handling via Form PAR 101 is the default for our engagements.
Virginia Office of Tax Commissioner appeals
Administrative appeals of Virginia tax assessments are filed with the Tax Commissioner within 90 days under Va. Code § 58.1-1821. The Commissioner issues a written final determination through Public Documents and Rulings. Judicial review proceeds in a Virginia Circuit Court — for Portsmouth taxpayers, the Portsmouth Circuit Court — under Va. Code § 58.1-1825.
IRS Independent Office of Appeals
The administrative-appeals body within the IRS that resolves cases without litigation. Hampton Roads cases route through the Appeals offices serving the mid-Atlantic region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.
U.S. District Court — Eastern District of Virginia, Norfolk 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 Eastern District of Virginia, Norfolk Division, at the Walter E. Hoffman U.S. Courthouse, 600 Granby Street, Norfolk, VA 23510 — or in the U.S. Court of Federal Claims. The Eastern District also handles federal-tax criminal matters originating in Portsmouth under IRC § 7201 and IRC § 7202.
City of Portsmouth Treasurer and Commissioner of the Revenue
The City of Portsmouth Treasurer at 801 Crawford Street, Portsmouth, VA 23704 collects local property taxes, business-license tax, and personal-property tax. The Commissioner of the Revenue at the same address performs the assessor function and administers business license (BPOL) tax under Va. Code § 58.1-3700 et seq. and tangible personal property tax under § 58.1-3500 et seq.
Taxpayer Advocate Service — Richmond
An independent organization within the IRS that helps when normal channels stall. The Richmond TAS office serves Virginia. Page: taxpayeradvocate.irs.gov. Form 911 starts the case.
Speak with a tax attorney about your Portsmouth matter
Free consultation, attorney-client privileged under IRC § 7525, no obligation. If a Notice of Deficiency, Final Notice of Intent to Levy, or Virginia Department of Taxation assessment is in front of you, the deadline to respond is real and short — call today. Bring your most recent IRS notice, your last filed return, and any Virginia Tax correspondence to the consultation.
Frequently asked questions — Portsmouth tax
Does Virginia have a state income tax?
Yes. Virginia operates a graduated personal income tax under Va. Code § 58.1-320 with brackets from 2% to a top rate of 5.75% on taxable income above $17,000. The Commonwealth also levies a flat 6% corporate income tax under Va. Code § 58.1-400, a 4.3% state sales-and-use tax that combines with a 1% Portsmouth local option and a 0.7% Hampton Roads regional transportation rate for a 6% combined sales-tax rate, and a 5.75% withholding rate on employer payroll. The Virginia Department of Taxation administers all state-level taxes for Portsmouth residents and businesses. There is no Virginia state estate tax — only federal estate-tax exposure under IRC § 2001.
Where is the closest U.S. Tax Court trial location to Portsmouth?
Across the Elizabeth River in Norfolk — about five miles from Olde Towne. The U.S. Tax Court calendars Hampton Roads cases at the Walter E. Hoffman U.S. Courthouse, 600 Granby Street, Norfolk, VA 23510, the same building that hosts the U.S. District Court for the Eastern District of Virginia, Norfolk Division. A petitioner designates the preferred place of trial on the Tax Court petition under Tax Court Rule 140; Portsmouth-resident taxpayers typically designate Norfolk for the obvious proximity reason. Richmond is the other Virginia trial location, about 90 miles northwest along I-64.
What is the federal Collection Statute Expiration Date?
The IRS has ten years from the date of assessment to collect a federal tax under IRC § 6502. After that date, the debt is extinguished by operation of law. The clock pauses (tolls) during a pending Offer in Compromise, a Collection Due Process appeal, bankruptcy, a requested installment agreement, periods the taxpayer is outside the United States for six months or more, and — for active-duty service members and qualifying Navy reservists — during the period of service plus 180 days under the Servicemembers Civil Relief Act at 50 U.S.C. § 3991. Pulling account transcripts and calculating the exact CSED on each assessed year is the first analytical step on any Portsmouth collection case.
Why is Portsmouth called an independent city rather than part of a county?
Virginia is one of three states (with Maryland having Baltimore City, and Missouri having St. Louis City) where certain cities are legally independent of any county. Virginia has 38 independent cities, the most of any state. Portsmouth was incorporated in 1752 and granted city status in 1858. An independent city has no county government overlaid on it — the city itself collects local property tax through the City of Portsmouth Treasurer, performs assessments through the Commissioner of the Revenue, records deeds and Notices of Federal Tax Lien at the Portsmouth Circuit Court Clerk, and runs its own school division. For tax-attorney work, this means there is no separate “county” lien recordation office to check — the Portsmouth Circuit Court Clerk at 601 Crawford Street is the single recorder of record.
I work at Norfolk Naval Shipyard and hold a Q clearance. How does a tax debt affect my clearance?
Federal background-investigation adjudicative guidelines treat unresolved tax debt as a financial-considerations issue under SEAD 4, Adjudicative Guideline F. For Q-clearance and naval-reactor-class clearance work tied to Norfolk Naval Shipyard nuclear-reactor maintenance, refueling, and submarine refit — the shipyard sits on the Portsmouth bank of the Elizabeth River and has operated continuously since 1767 — the Department of Energy, Naval Reactors, and the Defense Counterintelligence and Security Agency look at unfiled returns, delinquent balances, and active liens on the SF-86. A documented payment plan or accepted Offer in Compromise typically satisfies the mitigating-conditions standard; ignoring the debt is what creates the problem. We coordinate Form 656 or Form 9465 timing with clearance reinvestigation cycles where the client’s job depends on it.
Can I be audited by both the IRS and the Virginia Department of Taxation for the same period?
Yes. The IRS examines federal income tax, federal employment tax, and federal excise tax. The Virginia Department of Taxation examines Virginia personal income tax, corporate income tax, sales-and-use tax, pass-through entity tax, and employer withholding. A Portsmouth taxpayer can simultaneously face an IRS Schedule C audit and a Virginia adjustment that follows automatically from the federal change. Information-sharing agreements between the IRS and the Department of Taxation mean a federal CP2000 or Notice of Deficiency typically triggers a corresponding Virginia adjustment within 90 to 180 days. We run both tracks in parallel from intake.
Does Virginia have an Offer in Compromise program?
Yes. The Virginia Department of Taxation may compromise state tax liabilities under Va. Code § 58.1-105 on grounds of doubt as to liability, doubt as to collectibility, or where collection of the full amount would be inequitable. The state OIC is filed on Form OIC B-3 (business) or OIC I-3 (individual) along with a full financial-disclosure package. The state program is narrower than the IRS OIC under IRC § 7122 and tends to focus on doubt-as-to-liability cases more than collectibility cases. For most Portsmouth engagements, the federal Offer carries the bigger dollar exposure; the state Offer follows on the same financial-disclosure backbone.
Can a California-Bar-admitted attorney represent me in Portsmouth?
For federal IRS matters — yes. Federal tax practice is governed by Treasury under 31 CFR Part 10 (Circular 230); the IRS accepts Form 2848 Power of Attorney from any attorney in good standing with any state bar. The U.S. Tax Court is a single federal court with nationwide jurisdiction; an attorney admitted to that court may represent a taxpayer at any Tax Court trial location, including the Norfolk session that serves Portsmouth and the wider Hampton Roads. For Virginia Department of Taxation administrative work, we file Form PAR 101 and handle the matter remotely. For Virginia state-court litigation — a Portsmouth Circuit Court judicial-review action under Va. Code § 58.1-1825, for instance — we associate with locally admitted Virginia counsel. The bulk of Portsmouth engagements never reach state court.
I claim the Earned Income Tax Credit. What should I know about IRS EITC audits?
EITC under IRC § 32 is one of the most heavily audited individual-tax provisions, particularly on qualifying-child residency under IRC § 152(c)(1)(B) and the joint-return test. Portsmouth working households claiming EITC for qualifying children should keep school enrollment records, medical records, lease or utility statements, and SNAP/TANF or other benefits enrollment records that tie the child to the claimant’s address. A disallowed EITC claim can trigger a two-year ban under IRC § 32(k)(1)(B)(ii) (for reckless or intentional disregard) or a ten-year ban (for fraud), on top of credit recapture and accuracy-related penalty exposure under § 6662. Most disallowances are reversible on properly documented audit-reconsideration filings — the documentation just has to be assembled.
I am a Filipino-American Portsmouth resident with family accounts in the Philippines. What FBAR obligations apply?
If the aggregate value of all your foreign financial accounts exceeded $10,000 at any point during the calendar year, FinCEN Form 114 (FBAR) is required under 31 U.S.C. § 5314. Hampton Roads — Portsmouth included — hosts a long-established Filipino-American Navy population tied to wartime Filipino enlistment in the U.S. Navy, first as stewards’ mates and later across the full service. Joint accounts in Manila, Cebu, Iloilo, Davao, and Bacolod are common. FBAR penalties for non-willful violations are capped at $10,000 per violation (adjusted for inflation); willful violations under 31 U.S.C. § 5321(a)(5) reach the greater of $100,000 or 50% of the account balance, per year. The IRS Streamlined Filing Compliance Procedures provide a non-willful disclosure path for taxpayers who file three years of amended returns, six years of FBARs, and a sworn statement of non-willfulness. Streamlined Domestic and Streamlined Foreign tracks differ on residency.
I work at Jefferson Lab in Newport News. What tax issues come up most often?
The Thomas Jefferson National Accelerator Facility is a U.S. Department of Energy national laboratory operated under DOE contract for nuclear-physics research. Tax issues that recur for Jefferson Lab staff and Portsmouth-resident commuters: post-doctoral fellowship reporting under IRC § 117(c) (the service-rendering portion is taxable wages, not excluded scholarship), classified research-and-experimental expenditure capitalization under IRC § 174 as amended by TCJA, foreign-collaborator tax treaty positions under IRC § 894 for visiting international researchers, Q-clearance compliance posture on personal financial issues, and excess-itemized-deduction recapture on relocation reimbursements that are no longer excludable under IRC § 132(g) post-2017. We have handled the full spectrum.
What is the Virginia Pass-Through Entity Tax (PTET) and should my Portsmouth business elect it?
Va. Code § 58.1-390.3 lets a qualifying pass-through entity (S-corp, LLC taxed as partnership, partnership) elect to pay Virginia income tax at the entity level rather than at the owner level. The election sidesteps the federal $10,000 SALT cap under IRC § 164(b)(6) by converting what would be a non-deductible owner-level state-tax payment into a deductible entity-level expense. For a Portsmouth S-corp owner paying $30,000 in Virginia tax, the election can produce roughly $7,000 to $10,000 in federal tax savings annually depending on bracket. The election is made on Form 502PTET and is annual — missed deadlines or defective elections produce refile and amended-return work. Whether the election makes sense depends on owner composition, basis posture, and SALT-cap interaction; we run the math case-by-case.
I run a High Street restaurant. What sales-tax and Trust Fund Recovery Penalty exposure should I know about?
A Portsmouth Olde Towne restaurant or hospitality LLC must collect the 6% combined Virginia sales tax (4.3% state + 1% Portsmouth local + 0.7% Hampton Roads regional) plus the Portsmouth meals tax on prepared food and beverages, then remit through ST-9 monthly filings. Sales tax held but not remitted is a trust-fund obligation: the Virginia Department of Taxation can pursue officers personally under Va. Code § 58.1-1813, and the IRS can pursue federal Trust Fund Recovery Penalty liability under IRC § 6672 on the federal Form 941 withholding side. The Form 4180 interview is the qualification mechanism on the federal side. Willful failure to collect or pay over withheld tax under IRC § 7202 raises criminal exposure that runs alongside the civil penalty — an exposure we encounter regularly in cash-heavy High Street and Crawford Street operations.
Can the IRS levy my Portsmouth 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 Navy Federal Credit Union, Towne Bank, Truist, Atlantic Union Bank, Wells Fargo, JPMorgan Chase, or any Portsmouth-licensed institution, and serve wage levies on Norfolk Naval Shipyard civilian-employee payroll, Naval Medical Center Portsmouth staff payroll, Bon Secours Maryview Medical Center, Jefferson Lab contractors, the City of Portsmouth, Portsmouth Public Schools, and other Hampton Roads employers. For Norfolk Naval Shipyard civilian DOD workers, DFAS Indianapolis Civilian Pay processes the federal payroll levy through its own routing. A timely Form 12153 CDP request halts collection while the case is reviewed by the IRS Independent Office of Appeals. After a CDP determination, the taxpayer has 30 days to petition the U.S. Tax Court under IRC § 6330(d)(1).
How long does a federal Offer in Compromise take to process?
A federal 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; the firm’s Portsmouth Offer files run through standardized intake to minimize Returned-as-Incomplete kickbacks. A parallel Virginia Form OIC B-3 or OIC I-3 typically resolves on a similar timeline.
Will hiring a tax attorney stop IRS and Virginia Tax collection immediately?
Once Form 2848 is on file with the IRS, the agency routes all communication through the attorney and stops contacting the taxpayer directly. Form PAR 101 produces the same redirection at the Virginia Department of Taxation. Active levies are not automatically lifted by 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. Virginia state collection follows a separate § 58.1-1802.1 limitation track requiring its own analysis and submissions.
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 a Hampton Roads case load that includes Norfolk Naval Shipyard civilian DOD shipbuilders holding Q and naval-reactor-class clearances, Naval Medical Center Portsmouth 1099 physicians, Jefferson Lab DOE researchers, Filipino-American Navy families, African-American working households claiming EITC, Olde Towne and High Street small-business operators, and Hispanic Portsmouth residents handling ITIN and Streamlined Filing matters.
Page last reviewed: . Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Virginia statute citation links to law.lis.virginia.gov. 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 Virginia Department of Taxation, the U.S. Tax Court, the Virginia Office of Tax Commissioner, 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 Virginia; where a Virginia state-court appearance is required, the firm associates with locally admitted counsel. Virginia Department of Taxation administrative matters are handled remotely via Form PAR 101.
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
Virginia Tax Attorney
Statewide hub
Authorities cited on this page
- 26 U.S.C. § 7122 — Federal Offer in Compromise
- 26 U.S.C. § 6159 — Installment Agreements
- 26 U.S.C. § 6321 — Federal Tax Lien
- 26 U.S.C. § 6325 — Lien Release and Discharge
- 26 U.S.C. § 6331 — Levy and Distraint
- 26 U.S.C. § 6343 — Release of Levy
- 26 U.S.C. § 6502 — Collection Statute Expiration
- 26 U.S.C. § 6213 — Tax Court Petition Window
- 26 U.S.C. § 6320 — CDP for Liens
- 26 U.S.C. § 6330 — CDP for Levies
- 26 U.S.C. § 6651 — Failure-to-File and Failure-to-Pay
- 26 U.S.C. § 6672 — Trust Fund Recovery Penalty
- 26 U.S.C. § 7202 — Willful Failure to Collect or Pay Over
- 26 U.S.C. § 6015 — Innocent Spouse Relief
- 26 U.S.C. § 32 — Earned Income Tax Credit
- 26 U.S.C. § 117 — Qualified Scholarships
- 26 U.S.C. § 174 — Research and Experimental Expenditures
- 26 U.S.C. § 7508 — Combat-Zone Deadline Postponement
- 26 U.S.C. § 7508A — Disaster Deadline Postponement
- 26 U.S.C. § 165 — Casualty Losses
- 26 U.S.C. § 1033 — Involuntary Conversions
- 26 U.S.C. § 7345 — Passport Revocation
- 26 U.S.C. § 164(b)(6) — Federal SALT Cap
- Va. Code § 58.1-320 — Virginia Personal Income Tax (top 5.75%)
- Va. Code § 58.1-400 — Virginia Corporate Income Tax (6%)
- Va. Code § 58.1-390.3 — Virginia Pass-Through Entity Tax (PTET)
- Va. Code § 58.1-1821 — Administrative Appeal to Tax Commissioner
- Va. Code § 58.1-1825 — Circuit Court Judicial Review
- Va. Code § 58.1-1813 — Officer Liability for Trust-Fund Taxes
- Va. Code § 58.1-105 — Virginia OIC Authority