Skip to main content

Tax Attorney in San Antonio, TX

Federal IRS representation for San Antonio individuals, military families, USAA-employed taxpayers, South Texas Medical Center physicians, and Eagle Ford royalty owners — audits, back taxes, liens, levies, Offer in Compromise filings, and U.S. Tax Court petitions tried in the Hipolito F. Garcia Federal Building. Texas levies no personal income tax, so most San Antonio engagements are pure federal-IRS work, with Texas Comptroller franchise or sales-tax matters handled remotely via Form 2848 Power of Attorney.

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

Serving Bexar County — San Antonio, Alamo Heights, Schertz, Universal City, Live Oak, Converse, Helotes, Leon Valley, and the greater San Antonio metro

$100M+

in tax relief secured

2,000+

resolved cases

5.0 / 72

Google reviews

U.S. Tax Court

admitted counsel

Last reviewed: Free consultation: (800) 883-8301 U.S. Tax Court — San Antonio trial sessions

San Antonio taxpayers facing IRS collection or Texas Comptroller action — the clock is short

An IRS CP504 or LT11 sets a 30-day clock under IRC § 6330 to file a Collection Due Process petition before the federal government can levy a USAA paycheck, a Frost Bank account, or a Joint Base San Antonio Service member's bank account on direct deposit. A Notice of Deficiency sets a separate 90-day clock under IRC § 6213(a) to petition the U.S. Tax Court, with trial sessions held at the Hipolito F. Garcia Federal Building at 615 E Houston Street — the same address that serves the Western District of Texas for federal-tax refund suits next door at 655 E Cesar E Chavez Blvd.

Texas has no state personal income tax, so for individual filers the federal side is the entire problem. For San Antonio business owners with Comptroller franchise-tax, sales-tax, or use-tax exposure, the state's four-year assessment period under Tex. Tax Code § 111.201 runs separately from the federal Collection Statute Expiration Date under IRC § 6502. We pull federal account transcripts, file Form 2848 with the IRS, calculate every CSED, and where state matters overlap, file the Comptroller's POA so the state and federal cases move together.

$100M+

aggregate tax relief

2,000+

federal cases resolved

5.0

Google rating (72 reviews)

50

states served via Form 2848

Federal tax representation for San Antonio taxpayers

Victory Tax Lawyers, LLP is a California-Bar-admitted tax-resolution law firm headquartered in Los Angeles. Our federal practice is nationwide: the Internal Revenue Service accepts our Form 2848 Power of Attorney in every state, and the U.S. Tax Court — one federal trial court of nationwide jurisdiction — holds permanent trial sessions in San Antonio. From our Robertson Boulevard office, we represent San Antonio residents and Bexar-County-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). Any attorney in good standing with any state bar may represent a taxpayer before the IRS in any state via 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 San Antonio engagements, no Texas-Bar admission is required at any stage of the case.

For Texas state tax matters — Comptroller of Public Accounts franchise tax, sales-and-use tax, or hearings before the State Office of Administrative Hearings — we file the Comptroller's POA and handle the matter remotely from Los Angeles. Where a Texas state-court appearance is required (a Travis County district-court judicial review of a SOAH decision, for example, or a state-court collection action), we associate with locally admitted Texas counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the larger exposure, stays with us.

San Antonio carries a tax profile shaped by Joint Base San Antonio — the consolidated Fort Sam Houston, Randolph Air Force Base, and Lackland Air Force Base footprint — the largest single concentration of U.S. military medical and cyber-operations personnel in the country. Add the USAA headquarters on Fredericksburg Road, the South Texas Medical Center physician corridor, Eagle Ford Shale royalty owners in the surrounding counties, and the city's role as the U.S. gateway to Mexico, and the federal-tax case-mix here looks different than Houston or Dallas. We frame every San Antonio engagement around those facts.

Your tax rights as a San Antonio taxpayer

Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights for Texas business taxpayers come from Tex. Tax Code Chapter 111 and the Comptroller's taxpayer-rights publications. There is no Texas state personal income tax, so individual San Antonio filers operate under the federal framework alone. Knowing both sides is the difference between a clean resolution and a missed deadline that ends in a wage levy or a Bexar County tax warrant.

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 Texas Comptroller honors a parallel POA on Form 86-113 for state 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 sits in San Antonio at the Hipolito F. Garcia Federal Building, 615 E Houston Street, with additional Texas trial sessions in Dallas, Houston, El Paso, and Lubbock.

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 Bexar County 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 a hearing on state assessments

For Texas Comptroller franchise or sales-tax determinations, Tex. Tax Code § 111.009 allows a redetermination request within 60 days of the notice. Contested cases are heard by the State Office of Administrative Hearings, with judicial review available in Travis County district court under Tex. Gov't Code Chapter 2001.

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, natural disaster, military deployment, 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 San Antonio 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 negotiate 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. Texas has no personal-income-tax mirror to the OIC; for Comptroller business-tax balances, we use the state's Voluntary Disclosure Agreement or a payment-plan negotiation under Tex. Tax Code § 111.103.

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 — the most under-used resolution path for San Antonio taxpayers carrying $50,000 to $250,000 in federal debt with a CSED running before full payment is realistic.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien filed with the Bexar County Clerk blocks a property sale or refinance in Alamo Heights, Stone Oak, the Dominion, or any Bexar County 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.

Levy release under IRC § 6343

Wage levies on USAA, H-E-B, Methodist Healthcare, Valero, and other San Antonio employers; bank levies on Frost, USAA Federal Savings, Wells Fargo, and JPMorgan Chase. 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 Eagle Ford royalty depletion under IRC § 613 and § 613A, FBAR FinCEN Form 114 for accounts in Monterrey or Mexico City, S-corporation reasonable-compensation, military combat-zone exclusions under IRC § 112, and South Texas Medical Center 1099 physician work. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window for trial in San Antonio.

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 active-duty Joint Base San Antonio service members.

Twelve types of San Antonio tax matters we handle

Federal-tax cases for San Antonio residents and businesses, framed against the city's military, financial-services, energy, and cross-border economic profile.

Military combat-zone exclusion disputes

IRC § 112 excludes combat-zone pay for active-duty service members deployed from Joint Base San Antonio. CP2000 mismatches on excluded pay, hostile-fire-pay reporting, and tax-free housing allowances under IRC § 134 are routine adjustments where the W-2 box-1 amount was wrong.

Military spouse residency (MSRRA)

The Military Spouses Residency Relief Act allows a spouse stationed at Fort Sam Houston, Randolph AFB, or Lackland AFB to retain a non-Texas domicile (or claim Texas as the no-PIT domicile) without state-tax assessment by the home state of record. Coordination with the home-state department of revenue is regular work.

Servicemembers Civil Relief Act (SCRA) tax tolling

SCRA, 50 U.S.C. § 3991, tolls IRS collection limitation periods during periods of active military service plus 180 days. For Joint Base San Antonio deployed personnel, this changes the CSED math on every assessed year — both extending taxpayer rights and complicating collection planning.

Eagle Ford Shale royalty disputes

San Antonio sits above the Eagle Ford Shale play. Mineral-rights owners receive 1099-MISC royalty income subject to percentage depletion under IRC § 613A. Audit issues include depletion-calculation errors, the “65% taxable income” limitation, working-interest vs. royalty-interest classification, and intangible drilling cost deductions under IRC § 263(c).

FBAR for Mexican accounts

San Antonio sits 150 miles from the Laredo border crossing. Cross-border banking is common — family accounts in Monterrey, Saltillo, and Mexico City. FinCEN Form 114 (FBAR) is required for aggregate balances over $10,000. Streamlined Filing Compliance Procedures are the most common engagement for unreported accounts.

USAA-employee tax balances

USAA's San Antonio headquarters employs financial-services W-2 staff and a parallel population of 1099 contract underwriters, claims handlers, and tech contractors. Mixed-status filers routinely under-withhold; first IRS CP14 lands the following spring with penalties under IRC § 6654 for failure to make estimated payments.

South Texas Medical Center 1099 physicians

Methodist, Baptist, University Hospital, and the San Antonio Military Medical Center generate substantial 1099 contractor work for anesthesiologists, radiologists, and locum-tenens physicians. Schedule C reporting, self-employment tax under IRC § 1401, and quarterly estimated-tax compliance under IRC § 6654 are the recurring audit issues.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. San Antonio restaurant, construction, and oilfield-services owners are the most common targets, with the IRS Form 4180 interview as the qualification mechanism.

River Walk hospitality W-2G

San Antonio's tourism economy — the River Walk, the Alamo, Six Flags Fiesta Texas, SeaWorld — produces hospitality W-2G winnings, 1099-K third-party-network reporting for short-term rental hosts, and unreported tip-income exposure under IRC § 3121(q).

Notice of Federal Tax Lien

NFTLs filed with the Bexar County Clerk encumber title to San Antonio real property and trigger Collection Due Process rights under IRC § 6320. Stone Oak, the Dominion, Olmos Park, and Terrell Hills are the addresses where lien-discharge filings most often run alongside a residential closing.

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 San Antonio's military, cross-border, and international-business population, this is a common engagement requiring IRC § 7345(e) reversal.

Currently Not Collectible status

When household allowable expenses under the IRS Collection Financial Standards exceed income, we file Form 433-F or 433-A and place the account in CNC status under IRM 5.16.1, freezing levy and seizure activity while the CSED continues to run.

Nine common causes of tax debt for San Antonio taxpayers

Patterns we see repeatedly across San Antonio cases. None of them are unusual — all of them are resolvable.

1. Eagle Ford royalty windfalls

A San Antonio landowner receives a 1099-MISC for Eagle Ford royalty income without quarterly estimated-tax payments. The following April brings a five- or six-figure federal liability plus IRC § 6654 estimated-tax penalties.

2. Military combat-zone misreporting

A Joint Base San Antonio service member returns from a deployment where pay should have been excluded under IRC § 112. A W-2 reporting error or DFAS coding mistake leaves taxable wages overstated and a return owed money back rather than collecting a refund.

3. Locum-tenens physician undertaxation

A South Texas Medical Center anesthesiologist taking locum-tenens 1099 work without making quarterly Form 1040-ES payments faces self-employment tax under IRC § 1401 plus accuracy-related penalty exposure under IRC § 6662.

4. Business closure with unpaid Form 941

A San Antonio 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.

5. Divorce and joint-return fallout

A jointly-filed return tied to a now-former spouse's understatement leaves both parties liable until Innocent Spouse relief under IRC § 6015 is granted. Bexar County family-court orders do not bind the IRS.

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, a recurring issue across the San Antonio tech and military-cyber population.

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.

8. Real-estate sale without estimated tax

A Stone Oak, Alamo Heights, or Boerne 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.

9. Stock-option exercise without planning

USAA and Rackspace alumni exercising ISOs trigger AMT under IRC § 55. NSO disqualifying dispositions generate ordinary-income inclusions that land squarely on the federal return without state-tax offset since Texas has no PIT.

Eight tax liabilities that pull in San Antonio taxpayers

Federal authority alongside the Texas statute where there is a parallel. Where the parallel does not exist (state PIT), the federal exposure stands alone.

Failure to file federal return

IRC § 6651(a)(1) imposes 5% per month, max 25%, plus interest under IRC § 6601. There is no Texas state-PIT mirror — the federal exposure carries the full weight.

Failure to file Texas franchise tax

Tex. Tax Code § 171.362 imposes 5% per month, max 10%, on unpaid franchise tax. Entity charter forfeiture under § 171.301 follows persistent non-compliance and triggers personal-officer liability under § 171.255.

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.

Texas sales-tax delinquency

Tex. Tax Code Chapter 151 imposes a 5% late-filing penalty, with an additional 5% if more than 30 days late. Personal liability for “responsible individuals” under § 111.0511 reaches officers, directors, and managers personally for unpaid state sales tax held in trust.

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid federal trust-fund employment tax (withheld income tax and employee FICA). The IRS uses Form 4180 interviews to identify responsible persons.

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.

Texas franchise-tax officer liability

When the Comptroller forfeits a Texas entity's charter under Tex. Tax Code § 171.255, officers and directors become personally liable for the entity's debts incurred during the forfeiture period — a tail that runs years past entity dissolution.

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. Texas family-business succession scenarios produce regular transferee-liability work.

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.

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.

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 Bexar County 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.

Why Victory Tax Lawyers for a San Antonio federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Texas-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 permanent San Antonio session at the Hipolito F. Garcia Federal Building. 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 San Antonio clients never need a separately admitted Texas attorney because the case is, at its core, federal.

When a matter does require Texas state-court appearance — a Travis County district-court judicial-review action on a State Office of Administrative Hearings decision, for example, or a Bexar County state-court collection matter — we coordinate with locally admitted Texas counsel under a co-counsel arrangement. The federal portion of the engagement, which is usually the bigger exposure, stays with us. State Comptroller administrative work runs remotely through the Comptroller's POA without requiring Texas-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 San Antonio client never drives anywhere — not to Los Angeles, not downtown to the federal courthouse on Houston Street unless trial requires it, not to the IRS Taxpayer Assistance Center on Datapoint Drive. 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 Texas-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any San Antonio taxpayer, at the same standard applied to a Los Angeles client.

Our seven-step process for San Antonio clients

1

Free consultation

A 30-minute call with a tax attorney to scope your matter, identify deadlines, and decide whether engagement is the right move.

2

Engagement letter

A written scope, fee structure, and conflict check. Flat fees for administrative resolution; hourly or hybrid for litigation.

3

Form 2848 and CAF

We file the federal Power of Attorney, register on the IRS Centralized Authorization File, and step in as the contact of record — including with the Texas Comptroller via POA where state matters overlap.

4

Transcript and CSED analysis

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

5

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/state coordination if applicable.

6

Filing and negotiation

We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, Tax Court Petition — and handle every IRS contact directly through the secure portal.

7

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 Texas state assessment limits

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 military — during the period of service plus 180 days under SCRA, 50 U.S.C. § 3991.

Texas has no state personal income tax, so no parallel state PIT collection clock runs against San Antonio individual filers. For Texas businesses, Tex. Tax Code § 111.201 generally limits the Comptroller's assessment of franchise tax, sales tax, and other state-administered taxes to four years after the tax became due. Fraud, failure to file, and signed waivers extend the period. For unpaid franchise tax leading to entity charter forfeiture, the § 171.255 personal-officer-liability tail can run separately and well past the original assessment window.

San Antonio tax authorities and venues

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

Internal Revenue Service — San Antonio TAC

The federal tax authority, at irs.gov. The San Antonio Taxpayer Assistance Center operates at 8122 Datapoint Drive, San Antonio, TX 78229. Appointments are required and can be scheduled through the IRS office locator or 844-545-5640.

U.S. Tax Court — San Antonio trial sessions

The United States Tax Court holds permanent trial sessions in San Antonio at the Hipolito F. Garcia Federal Building, 615 E Houston Street, San Antonio, TX 78205. Petitioners across South Texas and the Rio Grande Valley typically calendar to San Antonio rather than Houston or Dallas based on proximity.

Texas Comptroller of Public Accounts

The Texas state revenue authority, at comptroller.texas.gov. The Comptroller administers franchise tax under Tex. Tax Code Chapter 171, sales-and-use tax under Chapter 151, and other state-administered taxes. Headquartered at 111 E 17th Street, Austin, TX 78774. A San Antonio Comptroller field office serves Bexar County taxpayers; remote handling via the Comptroller's POA is the default for our engagements.

State Office of Administrative Hearings (SOAH)

The Texas State Office of Administrative Hearings hears state-tax redetermination cases referred by the Comptroller under Tex. Tax Code § 111.009. Administrative Law Judges issue proposals for decision; the Comptroller issues the final decision. Judicial review proceeds in Travis County district court under Tex. Gov't Code Chapter 2001.

IRS Independent Office of Appeals

The administrative-appeals body within the IRS that resolves cases without litigation. South Texas cases route through the Appeals offices serving the region. Filings: Form 9423 (collection appeal) and Form 12153 (CDP). Page: irs.gov/appeals.

U.S. District Court — Western District of Texas, San Antonio 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 Western District of Texas, San Antonio Division, at 655 E Cesar E Chavez Boulevard, San Antonio, TX 78206 — or in the U.S. Court of Federal Claims. The Western District also handles federal-tax criminal matters originating in Bexar County.

Bexar County Tax Assessor-Collector

The Bexar County Tax Assessor-Collector at 233 N Pecos La Trinidad, San Antonio, TX 78207, administers county property tax, motor-vehicle registration, and state-fee collection. Bexar County does not administer income tax (Texas has none), but the office is the recorder for Notices of Federal Tax Lien filed by the IRS against San Antonio real property.

Taxpayer Advocate Service — San Antonio

An independent organization within the IRS that helps when normal channels stall. The San Antonio TAS office serves South Texas. Page: taxpayeradvocate.irs.gov. Form 911 starts the case.

Speak with a tax attorney about your San Antonio matter

Free consultation, attorney-client privileged under IRC § 7525, no obligation. If a Notice of Deficiency or Final Notice of Intent to Levy 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 Texas Comptroller correspondence to the consultation.

Call (800) 883-8301 Free Consultation

Frequently asked questions — San Antonio tax

Does Texas have a state income tax?

No. Texas is one of nine states with no personal income tax. The state revenue authority is the Texas Comptroller of Public Accounts, which administers franchise tax under Tex. Tax Code Chapter 171 (a privilege tax on entities doing business in Texas), sales-and-use tax under Chapter 151, hotel-occupancy tax, motor-vehicle tax, and a handful of other state-administered taxes. For San Antonio individual filers, federal IRS exposure is the entire tax-liability picture — there is no state-income-tax mirror, no state collection statute on personal wages, and no state PIT audit overlay.

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

San Antonio itself. The U.S. Tax Court holds permanent-courtroom trial sessions at the Hipolito F. Garcia Federal Building, 615 E Houston Street, San Antonio, TX 78205. A petitioner designates the preferred place of trial on the Tax Court petition under Tax Court Rule 140; San Antonio-resident taxpayers typically designate San Antonio. Dallas, Houston, El Paso, and Lubbock are the other Texas trial locations. Rio Grande Valley and South Texas petitioners frequently route to San Antonio based on proximity.

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 Joint Base San Antonio service members — 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 San Antonio collection case.

Can I be audited by both the IRS and the Texas Comptroller for the same period?

Yes, but they audit different taxes. The IRS examines federal income tax, federal employment tax, and federal excise tax. The Texas Comptroller examines state franchise tax under Chapter 171, sales-and-use tax under Chapter 151, and other state-administered taxes. A San Antonio business can simultaneously face an IRS payroll audit (Form 941 issues) and a Comptroller sales-tax audit. The two agencies do share information through information-exchange agreements, and an adjustment in one forum often triggers a closer look at the other.

Does Texas have an Offer in Compromise program?

Not in the formal sense the IRS operates under IRC § 7122. The Texas Comptroller may negotiate settlements of disputed liabilities, accept payment plans, and waive penalties under Tex. Tax Code § 111.103 where reasonable cause exists. The Comptroller also runs a Voluntary Disclosure Agreement program for taxpayers who come forward with unreported state-tax obligations before being contacted. For the federal side, the IRS Offer in Compromise remains the standard mechanism for resolving a tax balance for less than the full amount when collectibility or liability is genuinely in doubt.

Can a California-Bar-admitted attorney represent me in San Antonio?

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 San Antonio. For Texas Comptroller franchise-tax or sales-tax administrative work, we file the Comptroller's POA and handle the matter remotely. For Texas state-court litigation — a Travis County district-court judicial-review action on a SOAH decision, for instance — we associate with locally admitted Texas counsel. The bulk of San Antonio engagements never reach state court.

I am active-duty military at Joint Base San Antonio. What special tax rules apply?

Several layers. IRC § 112 excludes combat-zone pay from gross income for service members deployed to designated combat zones. IRC § 7508 extends federal filing and payment deadlines during combat-zone service plus 180 days, and automatically abates failure-to-file and failure-to-pay penalties for the deployment period. The Servicemembers Civil Relief Act (SCRA) at 50 U.S.C. § 3991 tolls IRS collection limitation periods during military service. The Military Spouses Residency Relief Act (MSRRA) allows a non-Texas-domiciled spouse stationed at Fort Sam Houston, Randolph AFB, or Lackland AFB to retain the home state of record without Texas tax assessment (moot in Texas, which has no PIT, but it matters for spouses domiciled in a state with PIT). Audit and CP2000 issues on military pay coding are routine engagements.

I receive Eagle Ford Shale royalty income. What audit issues are most common?

Three recurring issues. First, depletion-calculation errors under IRC § 613 (cost depletion) and IRC § 613A (percentage depletion for oil-and-gas) — the 15% percentage-depletion rate is limited by the 65% taxable income cap and by the 1,000-barrel-per-day independent-producer ceiling. Second, working-interest vs. royalty-interest classification — a working interest is subject to self-employment tax under IRC § 1402(a)(1); a royalty interest is not. Misclassification produces material adjustments. Third, intangible drilling cost deductions under IRC § 263(c) for working-interest owners — expensing vs. capitalization elections are scrutinized in field audits. Eagle Ford engagements often involve South Texas landowners with multi-county mineral acreage and complex Form 4835 farm-rental reporting layers.

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 an Offer. Refunds claimed on returns filed more than three years after the original due date are time-barred under IRC § 6511(b)(2). Texas has no state PIT filing obligation, so there is no state-side filing compliance gap to close on personal returns; Texas businesses with unfiled franchise-tax reports may use the Comptroller's Voluntary Disclosure Agreement program.

Can the IRS levy my San Antonio 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 Frost Bank, USAA Federal Savings, Wells Fargo, JPMorgan Chase, or any San Antonio-licensed institution, and serve wage levies on USAA, H-E-B, Methodist Healthcare, Valero, Rackspace, and other Bexar County employers. 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). For active-duty service members at Joint Base San Antonio, additional SCRA protections apply.

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 San Antonio Offer files run through standardized intake to minimize Returned-as-Incomplete kickbacks.

What is the federal Trust Fund Recovery Penalty and who is at risk in San Antonio?

The Trust Fund Recovery Penalty under IRC § 6672 imposes 100% personal liability on responsible persons — officers, directors, partners, check-signers, payroll managers — for the trust-fund portion (withheld income tax and employee FICA) of unpaid Form 941 employment taxes. San Antonio restaurants on the River Walk, construction firms working Bexar County and the surrounding counties, oilfield-services contractors operating in the Eagle Ford, and hospitality operators in Alamo Plaza are the most common targets. The IRS uses Form 4180 interviews to identify responsible persons. Defense centers on lack of willfulness, lack of authority over the funds, and lack of knowledge of the unpaid trust-fund balance.

I have a Mexican bank account. Do I need to file an FBAR?

If the aggregate value of all your foreign financial accounts exceeded $10,000 at any point during the calendar year, yes — FinCEN Form 114 (FBAR) is required. San Antonio's proximity to the Mexico border (150 miles to Laredo) means cross-border banking is common — family accounts in Monterrey, Saltillo, Mexico City, and Guadalajara. FBAR penalties for non-willful violations are capped at $10,000 per violation; willful violations reach the greater of $100,000 or 50% of the account balance. The IRS Streamlined Filing Compliance Procedures provide a non-willful disclosure path for taxpayers who file three years of amended returns and six years of FBARs along with a sworn statement of non-willfulness. Streamlined Domestic and Streamlined Foreign tracks differ on residency.

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. For active-duty Joint Base San Antonio clients, SCRA stay-of-collection rights add another layer. Texas Comptroller collection on state matters follows a separate track requiring the Comptroller's POA and a state-side payment-plan or VDA submission.

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, with a substantial South Texas case load including Joint Base San Antonio military families, USAA-employed professionals, South Texas Medical Center physicians, and Eagle Ford royalty owners.

Page last reviewed: . Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Texas statute citation links to statutes.capitol.texas.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 Texas Comptroller of Public Accounts, the U.S. Tax Court, the State Office of Administrative Hearings, or other adjudicating body.

Victory Tax Lawyers, LLP is California-Bar-admitted with its principal office at 1100 S. Robertson Blvd., Los Angeles, CA 90035. The firm represents clients in federal tax matters nationwide via Form 2848 Power of Attorney and admission to the United States Tax Court. The firm is not admitted to practice in the courts of the State of Texas; where a Texas state-court appearance is required, the firm associates with locally admitted counsel. Texas Comptroller administrative matters are handled remotely via the Comptroller's POA.

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

Texas Tax Attorney

Statewide hub

Authorities cited on this page