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Tax Attorney in St. Petersburg, FL

Federal IRS representation for St. Petersburg individuals and businesses — audits, back taxes, liens, levies, payroll-tax disputes, FBAR disclosures, equity-compensation matters for Raymond James and Jabil employees, and U.S. Tax Court litigation at the Sam M. Gibbons U.S. Courthouse 25 miles north in Tampa. We also coordinate Florida Department of Revenue matters under IRS Form 2848 and Florida Form DR-835 Power of Attorney where they sit alongside a federal case.

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

Serving Pinellas County, St. Pete Beach, Treasure Island, Madeira Beach, and the greater Tampa Bay area

$91M+

in tax relief secured

2,000+

resolved cases

5.0 / 72

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U.S. Tax Court

admitted counsel

Last reviewed: · Reviewed by Parham Khorsandi, Esq.

Free consultation: (800) 883-8301

If you owe back taxes in St. Petersburg, here is the 2026 picture

Florida has no state personal income tax under Fla. Const. art. VII, § 5 — for individual St. Petersburg taxpayers, the entire income-tax exposure sits at the federal level under IRC Subtitle A. The state tax picture is built around three other pieces: a 5.5% Florida Corporate Income Tax under Fla. Stat. ch. 220 (with the limited exemption for entities taxed as partnerships or S-corps); 6% state sales and use tax plus a 1% Pinellas County discretionary surtax for a 7% combined rate in St. Petersburg under Fla. Stat. ch. 212; and Florida Documentary Stamp Tax on deeds and notes under Fla. Stat. ch. 201. Disputes with the Florida Department of Revenue run through informal protest with the Department, then formal administrative appeal at the Division of Administrative Hearings under Fla. Stat. ch. 120.

If you have received an IRS CP504, an LT11 Final Notice of Intent to Levy, a Statutory Notice of Deficiency, or a Florida DOR Notice of Proposed Assessment or Notice of Decision, the deadlines are short. We pull your IRS account transcripts, calculate your Collection Statute Expiration Date under IRC § 6502, file Form 2848 Power of Attorney with the IRS and Form DR-835 with the Florida DOR, and put administrative brakes on collection while the case is built. Pinellas County tax warrants are recorded with the Clerk of the Circuit Court at 315 Court Street, Clearwater — 25 miles north of downtown St. Pete.

Federal tax representation for St. Petersburg taxpayers

Victory Tax Lawyers, LLP is a California-Bar-admitted tax-resolution law firm based in Los Angeles. Our federal practice runs nationwide. The Internal Revenue Service accepts our Form 2848 Power of Attorney in every state, and the U.S. Tax Court — a single federal tribunal with jurisdiction over IRS deficiency cases under IRC § 6213(a) — holds regular trial sessions in Tampa at the Sam M. Gibbons U.S. Courthouse, 801 N Florida Avenue, 25 miles north of downtown St. Petersburg. From our Robertson Boulevard office in Los Angeles, we represent St. Petersburg-area residents and Florida-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, FBAR disclosures under 31 U.S.C. § 5314, and Trust Fund Recovery Penalty defenses under IRC § 6672.

For Florida state tax matters — the 5.5% Florida Corporate Income Tax under Fla. Stat. ch. 220, sales and use tax disputes under Fla. Stat. ch. 212 (6% state plus 1% Pinellas discretionary, total 7% in St. Petersburg), documentary stamp tax under Fla. Stat. ch. 201, reemployment (unemployment) tax under Fla. Stat. ch. 443, and contested matters headed to the Division of Administrative Hearings (DOAH) — we file Form DR-835 Power of Attorney with the Department of Revenue and handle the administrative protest track directly. For formal litigation at DOAH, in Florida circuit court, or in the Florida District Courts of Appeal, we coordinate with locally admitted Florida counsel under a co-counsel arrangement. The federal portion of the engagement — usually the larger exposure for high-income St. Pete taxpayers, given Florida's absence of personal income tax — stays with our firm.

St. Petersburg sits at the intersection of several distinct tax-exposure economies. Raymond James Financial, the Fortune 500 wealth-management firm headquartered at 880 Carillon Parkway, drives a steady volume of RSU, ISO, performance-share unit (PSU), and IRC § 1061 carried-interest matters along with IRC § 199A specified-service-trade-or-business analyses for partner-level financial advisors. Jabil Inc., the Fortune 500 electronic manufacturing services company headquartered at 10560 Dr. Martin Luther King Jr. Street N, generates W-2 RSU vest events, ISO exercises, IRC § 174 research-and-experimentation capitalization issues, and Schedule C 1099 supplier matters. The Tampa Bay Rays at Tropicana Field, the Tampa Bay Buccaneers training facility, and the Tampa Bay Lightning across the bay drive pro-athlete jock-tax allocation under IRC § 61, endorsement 1099 income, and Florida-domicile elections. Home Shopping Network (HSN) and Qurate Retail at 1 HSN Drive generate 1099 direct-marketing contractor exposure. Bayfront Health, Johns Hopkins All Children's Hospital, and St. Anthony's Hospital contract heavily with 1099 physicians and locum-tenens providers. The University of South Florida St. Petersburg, Eckerd College, and Stetson University College of Law in Gulfport produce IRC § 117(c) post-doctoral and graduate-stipend issues plus IRC § 107 parsonage-allowance matters for chaplains and religious-school clergy. Pinellas County beach tourism on St. Pete Beach, Madeira Beach, Treasure Island, and Pass-a-Grille drives short-term-rental classification fights under IRC § 280A and passive-activity matters under IRC § 469. Hurricanes Ian (2022), Idalia (2023), Helene (2024), and Milton (2024) layered casualty-loss claims under IRC § 165(h), involuntary-conversion deferrals under IRC § 1033, and deadline tolling under IRC § 7508A on top of every existing case. Large Cuban-American, Puerto Rican, Filipino, and Vietnamese communities create FBAR disclosures under 31 U.S.C. § 5314, Streamlined Filing Compliance Procedures filings, and ITIN W-7 work. The federal procedures are uniform; the facts are St. Petersburg-specific.

Your tax rights as a St. Petersburg taxpayer

Two parallel rights frameworks apply when you owe tax. Federal rights come from the Internal Revenue Code and IRS Publication 1, the Taxpayer Bill of Rights. State rights for Florida taxpayers come from the Florida Taxpayer's Bill of Rights at Fla. Stat. § 213.015, administered through the Florida Department of Revenue, and from the Administrative Procedure Act at Fla. Stat. ch. 120, which governs how a disputed Florida DOR assessment reaches the Division of Administrative Hearings. Knowing both is the difference between a clean resolution and a missed 60-day DOAH petition window that ends in a final Florida assessment against your St. Petersburg business or beachfront property.

Right to representation

IRC § 7521(b)(2) and (c) give you the right to be represented by an attorney, CPA, or Enrolled Agent during any IRS examination or interview. Once Form 2848 is on file, the IRS routes communication through us, not you. Florida mirrors this through Form DR-835 Power of Attorney filed with the Florida Department of Revenue.

Right to U.S. Tax Court review

IRC § 6213(a) gives you 90 days from a Statutory Notice of Deficiency to petition the U.S. Tax Court without paying the tax first. Miss the 90 days and the federal assessment becomes final. The Tax Court holds regular trial sessions for St. Petersburg taxpayers in Tampa at the Sam M. Gibbons U.S. Courthouse, 801 N Florida Avenue — the primary Florida trial city.

Florida Taxpayer's Bill of Rights

Fla. Stat. § 213.015 codifies twenty enumerated rights, including the right to written notice of audit findings, the right to an informal protest with the Florida DOR within 60 days of a Notice of Proposed Assessment, and the right to confidentiality of taxpayer information under Fla. Stat. § 213.053.

Right to DOAH review

Fla. Stat. § 72.011 and Fla. Stat. ch. 120 give a Florida taxpayer the choice, after a final Florida DOR Notice of Decision, to challenge the assessment either in circuit court (paying or bonding the tax under Fla. Stat. § 72.011(3)) or through an administrative proceeding at the Division of Administrative Hearings, 1230 Apalachee Parkway, Tallahassee. The petition deadline is 60 days from the Notice of Decision.

Collection Due Process

IRC § 6320 (lien) and IRC § 6330 (levy) give you a 30-day window to request a CDP hearing once the IRS files a Notice of Federal Tax Lien or issues a Final Notice of Intent to Levy. A timely Form 12153 filing halts collection and preserves judicial review through the U.S. Tax Court.

Right to settle for less than owed

Federally, IRC § 7122 authorizes Offers in Compromise based on doubt as to liability, doubt as to collectibility, or effective tax administration. Florida runs a parallel compromise authority under Fla. Stat. § 213.21, allowing the Department of Revenue to compromise penalties and, in narrower circumstances, tax based on doubt or hardship. Both programs require filing compliance before consideration.

Right to disaster relief

For St. Petersburg taxpayers affected by Hurricanes Ian, Idalia, Helene, and Milton, IRC § 7508A authorizes the IRS to postpone federal filing and payment deadlines for taxpayers in federally declared disaster areas. The Florida DOR issues parallel Tax Information Publications extending state filing deadlines for affected Pinellas County taxpayers under Fla. Stat. § 213.055.

Right to recover fees

IRC § 7430 allows recovery of administrative and litigation costs if the IRS takes a position that is not substantially justified and the taxpayer prevails. The threshold is high but real — we see it most often in audit reconsideration cases and Innocent Spouse relief matters under IRC § 6015.

How Victory Tax Lawyers helps St. Petersburg taxpayers

Offer in Compromise under IRC § 7122

We file Form 656 with Form 433-A(OIC) or 433-B(OIC), document the Reasonable Collection Potential, and negotiate doubt-as-to-collectibility offers when full collection is not feasible within the remaining CSED. For St. Petersburg taxpayers, the federal OIC is usually the entire compromise story — Florida has no personal income tax to settle. Where a Florida sales-tax, reemployment-tax, or corporate income tax balance is also outstanding, we run a Fla. Stat. § 213.21 compromise request on a parallel track.

Installment Agreements under IRC § 6159

Streamlined IAs (under $50,000), partial-pay IAs under IRC § 6159(d), and full-pay agreements. We push for partial-pay structures where the IRC § 6502 ten-year CSED will extinguish the balance before payoff — an under-used resolution path for St. Petersburg taxpayers in the $50,000 to $250,000 federal-debt range.

Lien discharge, subordination, and withdrawal

When a Notice of Federal Tax Lien blocks a St. Pete property sale or refinance, we file Form 14135 (discharge), Form 14134 (subordination), or Form 12277 (withdrawal). NFTLs are filed with the Pinellas County Clerk of the Circuit Court at 315 Court Street, Clearwater, and encumber title until cleared under IRC § 6325. Timing must align with the closing.

Levy release under IRC § 6343

Wage levies, bank levies on Raymond James Bank, Truist, Bank of America, Wells Fargo, Fifth Third, or any Florida-licensed institution, and accounts-receivable levies on St. Petersburg contractors. We document economic hardship under IRC § 6343(a)(1)(D) and Treasury Reg. § 301.6343-1(b)(4), and where the levy is procedurally defective we challenge it through Collection Due Process or Appeals. Florida sales-tax warrants follow a parallel state track under Fla. Stat. § 213.69.

Audit defense and U.S. Tax Court litigation

Correspondence audits, office audits, and field examinations — including sensitive issues like cryptocurrency, foreign accounts under FinCEN Form 114 (FBAR), S-corporation reasonable-compensation, short-term-rental classification on St. Pete Beach and Treasure Island properties, Raymond James and Jabil RSU/ISO matters, and casualty-loss claims from the 2022-2024 hurricane sequence. If the audit closes unfavorably, we petition the U.S. Tax Court within the 90-day IRC § 6213(a) window. Trial sessions for St. Petersburg cases are held in Tampa at the Sam M. Gibbons U.S. Courthouse.

Penalty abatement under IRC § 6651 and IRM 20.1.1

First-Time Abate administrative relief, reasonable-cause abatement, and statutory exceptions for failure-to-file and failure-to-pay penalties. On accuracy-related penalties under IRC § 6662, we document substantial authority or adequate disclosure to defeat the assessment. Florida sales-tax and reemployment-tax penalties under Fla. Stat. § 213.21 follow a separate reasonable-cause analysis administered through the Florida DOR.

Twelve types of St. Petersburg tax matters we handle

Federal cases for St. Petersburg-area residents and businesses, framed against the Florida DOR overlay where it matters.

Raymond James wealth-advisor compensation

Raymond James Financial's St. Petersburg headquarters drives a heavy volume of partner and senior-advisor compensation issues: RSU vest events taxed at the 22% supplemental rate, IRC § 1061 carried-interest holding periods, IRC § 199A specified-service-trade-or-business analysis (investment management is statutorily excluded under Treas. Reg. § 1.199A-5(b)(2)(xi)), and deferred-compensation timing under IRC § 409A. Underwithholding at the 22% federal supplemental rate against a 35% or 37% marginal bracket produces a six-figure April balance routinely.

Jabil RSU, ISO, and § 174 R&D capitalization

Jabil Inc., the Fortune 500 electronic manufacturing services company headquartered in St. Petersburg, issues RSUs and ISOs to engineers, managers, and executives. RSU underwithholding at the 22% supplemental rate, ISO disqualifying dispositions triggering AMT under IRC § 55, and the post-TCJA five-year capitalization rule for domestic R&D expenses under IRC § 174 are recurring issues. Jabil's Schedule C 1099 suppliers face self-employment tax and quarterly estimated-payment compliance under IRC § 6654.

Pro-athlete jock-tax for Rays, Bucs, Lightning

Tampa Bay Rays players at Tropicana Field, Buccaneers at their Tampa training facility, and Lightning across the bay claim Florida domicile precisely because Florida has no state personal income tax. Away-game days still create source-state income subject to jock-tax allocation under IRC § 61. We coordinate the duty-day allocation, defend the Florida domicile election against challenges from California, New York, and Illinois revenue departments, handle MLB minor-leaguer 1099 endorsement deals, and resolve any federal underpayment under IRC § 6654.

Short-term-rental classification on Pinellas beaches

St. Pete Beach, Treasure Island, Madeira Beach, and Pass-a-Grille short-term rentals raise the seven-day average-rental-period rule of Treas. Reg. § 1.469-1T(e)(3)(ii) and the IRC § 280A vacation-home limitations. Florida adds a transient rental tax under Fla. Stat. § 212.03 (combined 13% in Pinellas including the 6% tourist development tax). Misclassification creates both federal passive-activity disallowance under IRC § 469 and a state tax assessment.

Casualty losses from Ian, Idalia, Helene, Milton

Hurricanes Ian (2022), Idalia (2023), Helene (2024), and Milton (2024) hit Pinellas storm-surge zones hard — particularly the St. Pete Beach, Treasure Island, Madeira Beach, and Shore Acres neighborhoods. IRC § 165(h) limits personal casualty losses to federally declared disaster areas; IRC § 1033 defers gain on involuntary conversions when insurance or FEMA proceeds exceed basis; IRC § 7508A tolls filing and payment deadlines. We sort the timing of basis-recovery, insurance-proceed, and disaster-loss carrybacks.

Notice of Federal Tax Lien

NFTLs filed with the Pinellas County Clerk of the Circuit Court (315 Court Street, Clearwater) encumber title to St. Petersburg real property and trigger CDP rights under IRC § 6320. Florida's homestead exemption under Fla. Const. art. X, § 4 protects against state-creditor execution but does not block a federal tax lien — the supremacy of federal tax liens over state homestead protections is settled under United States v. Rodgers, 461 U.S. 677 (1983).

FBAR and FATCA non-disclosure

FinCEN Form 114 for foreign accounts over $10,000 aggregate is a frequent St. Petersburg engagement — the Cuban-American population, the Puerto Rican community, Filipino and Vietnamese families, and U.S. citizens with Caribbean and Latin American banking relationships all drive Streamlined Filing Compliance Procedures and Delinquent FBAR Submission cases under 31 U.S.C. § 5314. The FBAR willful-penalty rate is 50% of the account balance per year, capped under Bittner v. United States, 598 U.S. 85 (2023) for non-willful cases.

Trust Fund Recovery Penalty

IRC § 6672 imposes personal liability on officers, partners, and check-signers for unpaid employment-tax withholding. St. Petersburg restaurant, hospitality, marine-services, construction, and trucking owners are common targets. The IRS uses Form 4180 interviews to identify responsible persons; Florida parallels this with reemployment-tax personal liability under Fla. Stat. § 443.141.

1099 physician income at Bayfront and Johns Hopkins All Children's

Bayfront Health, Johns Hopkins All Children's Hospital, St. Anthony's Hospital, and the BayCare system contract heavily with 1099 physicians and locum-tenens providers. Self-employment tax at 15.3%, quarterly estimated payments under IRC § 6654, retirement-plan structuring (solo 401(k) or defined-benefit), and the Stark and anti-kickback compliance overlay all matter when a physician's federal balance crosses six figures.

USF St. Pete, Eckerd, and Stetson Law academic income

The University of South Florida St. Petersburg, Eckerd College, and Stetson University College of Law in Gulfport generate IRC § 117(c) post-doctoral and graduate-stipend issues (scholarship exclusion does not extend to teaching or research compensation), 1099-MISC adjunct-faculty income, and IRC § 107 parsonage-allowance matters for affiliated clergy and religious-school chaplains. We resolve assessments that misclassified stipend payments and rebuild correct Schedule SE filings.

HSN and Qurate 1099 direct-marketing

Home Shopping Network, Qurate Retail (post-2018 HSN-QVC merger), and the broader St. Petersburg direct-marketing industry contract on-air talent, demonstration hosts, and supply-chain vendors as 1099 independent contractors. Self-employment tax under IRC § 1401, home-office deduction substantiation under IRC § 280A(c)(1), and quarterly estimated-tax compliance under IRC § 6654 are routine engagements.

Passport revocation under IRC § 7345

A seriously delinquent tax debt (over $62,000 for 2025, indexed annually) triggers State Department certification and passport hold. With Tampa International Airport's heavy international traffic to Latin America and Europe, plus St. Pete-Clearwater International serving regional routes, passport-revoked taxpayers lose business and family travel overnight. We file the IRC § 7345(e) action to reverse the certification.

Nine common causes of tax debt for St. Petersburg taxpayers

Patterns we see repeatedly in St. Pete and Pinellas County engagements. None of them are unusual — all of them are resolvable.

1. RSU underwithholding

Raymond James, Jabil, and remote tech-worker RSU vest events generate W-2 inclusion taxed at the 22% federal supplemental rate — well below a 32%, 35%, or 37% marginal rate. The first IRS CP14 lands the following April with penalties under IRC § 6654. Because Florida has no PIT, the entire fix is federal: W-4 adjustment plus Form 1040-ES.

2. Self-employment underpayment

Locum-tenens physicians at Bayfront and Johns Hopkins All Children's, real-estate agents along the Gulf coast, charter-boat captains out of St. Pete Beach, HSN on-air talent, and Raymond James affiliated advisors file Schedule C or K-1 income with no estimated-tax payments. The first IRS CP14 lands with penalties under IRC § 6654.

3. Hurricane-driven cash crunch

Ian, Idalia, Helene, and Milton interrupted operations for St. Pete restaurants, marine businesses, and beach-front rentals. Even with IRC § 7508A deadline tolling, the next-cycle payroll, sales-tax, and quarterly estimated obligations come due before insurance proceeds clear. The result is a federal § 6672 trust-fund file and a Florida sales-tax warrant.

4. Business closure

When a St. Pete LLC or S-corp closes with unpaid Form 941 payroll-tax balances, IRC § 6672 follows the responsible officer personally — well after the entity is dissolved. Florida reemployment-tax personal liability under Fla. Stat. § 443.141 mirrors the federal trust-fund framework.

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. Florida is a non-community-property state, which simplifies allocation compared with California-based cases but does not change the federal joint-and-several liability rule.

6. Identity theft and fraudulent returns

A return filed in your name with refund redirected. Form 14039 opens the IRS identity-theft case; the assessment must be corrected, not just protested. Florida sees a higher rate of refund fraud than most states because of its retiree population concentrated in St. Petersburg, Clearwater, and the Pinellas suncoast.

7. 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. St. Pete's tech-migration population from New York, New Jersey, Illinois, and California over-indexes on crypto exposure.

8. 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. IRS Substitute-for-Return assessments under IRC § 6020(b) land on transcript before a taxpayer even knows the return is missing.

9. Real-estate sale without estimated tax

A Snell Isle, Old Northeast, Shore Acres, or beach-front sale generating substantial capital gain, with no Form 1040-ES payment, produces a tax bill the next April. Investor flips taxed at ordinary-income rates — not capital-gain — under the dealer-status rules. Florida Documentary Stamp Tax under Fla. Stat. ch. 201 adds a state cost at closing of $0.70 per $100 of consideration on the deed.

Eight tax liabilities that pull in St. Petersburg taxpayers

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

Failure to file federal return

IRC § 6651(a)(1) imposes 5%/month, max 25%, plus interest under IRC § 6601. Florida has no personal income tax, so there is no state-PIT failure-to-file analog. The Florida DOR's analogous penalties live in sales tax, corporate income tax, and reemployment tax under Fla. Stat. § 213.21.

Florida Corporate Income Tax

Fla. Stat. ch. 220 imposes a 5.5% Florida Corporate Income Tax on C-corporation taxable income, with the first $50,000 of net income exempt. Pass-through entities taxed as partnerships or S-corps are generally exempt at the state level. A late-filed Florida F-1120 triggers 10% per month failure-to-file penalty up to 50% under Fla. Stat. § 220.803.

Federal § 7122 Offer in Compromise eligibility

All federal returns must be filed (IRC § 7122(d) compliance) and the offer must reflect Reasonable Collection Potential. The non-refundable $205 application fee may be waived for low-income certified offers.

Florida sales and use tax

Fla. Stat. ch. 212 imposes 6% state plus a 1% Pinellas discretionary surtax, total 7% in St. Petersburg. Personal liability for responsible persons under Fla. Stat. § 213.29 pierces the corporate veil for trust-fund sales tax. The transient rental tax under Fla. Stat. § 212.03 adds another layer on short-term lodging in Pinellas (combined 13% with the tourist development tax).

Trust Fund Recovery Penalty

IRC § 6672 imposes 100% personal liability on responsible persons for unpaid trust-fund employment tax. Florida applies a similar responsible-person rule to reemployment-tax withholding under Fla. Stat. § 443.141 and to sales-tax collection under Fla. Stat. § 213.29.

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.

Florida Documentary Stamp Tax

Fla. Stat. ch. 201 imposes a documentary stamp tax on deeds, notes, and other written obligations — $0.70 per $100 of consideration on deeds outside Miami-Dade and $0.35 per $100 on the note. Failure-to-pay penalties under Fla. Stat. § 213.21 apply; closings on St. Petersburg real estate that omitted the stamp produce a later DOR assessment against the grantee.

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. Routine in St. Petersburg divorce, business-sale, and inheritance fact patterns.

What resolution can look like

Debt reduced

An accepted IRC § 7122 Offer in Compromise can resolve six-figure balances for a fraction of the original assessment where Reasonable Collection Potential supports the offer. National acceptance is roughly one in three; preparation determines the outcome.

Penalties abated

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

Lien released or withdrawn

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

Sample tax-resolution outcomes

Anonymized client matters drawn from our $91M+ 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 Florida Department of Revenue.

Why Victory Tax Lawyers for a St. Petersburg federal-tax case

Victory Tax Lawyers is California-Bar-admitted, not Florida-Bar-admitted. That distinction matters — and it does not block our work. The U.S. Tax Court is a federal court with nationwide jurisdiction; an attorney admitted to that court may petition and try cases at any of its trial locations, including Tampa at the Sam M. Gibbons U.S. Courthouse 25 miles north of downtown St. Pete. IRS administrative practice runs on Form 2848 Power of Attorney, accepted from any attorney in good standing with any state bar plus an active Centralized Authorization File number. Most of our St. Petersburg clients never need a separately admitted Florida attorney because the case is, at its core, federal. Florida's lack of a state personal income tax pushes that reality even further than in Georgia or California: for an individual St. Petersburg taxpayer, the income-tax fight is almost always federal-only.

For administrative work before the Florida Department of Revenue — sales-tax protests, corporate income tax audits, reemployment-tax audits, documentary stamp tax assessments, and compromise requests under Fla. Stat. § 213.21 — we file Form DR-835 Power of Attorney and handle the matter remotely. When a case must move to the Division of Administrative Hearings (DOAH, seated at 1230 Apalachee Parkway, Tallahassee), to circuit court under Fla. Stat. § 72.011, or to one of the Florida District Courts of Appeal, we coordinate with locally admitted Florida counsel under a co-counsel arrangement. The federal portion of the engagement — usually the larger exposure — stays with our firm.

What distinguishes our firm: a California-Bar-admitted managing attorney with active U.S. Tax Court admission, an Enrolled Agent on staff for IRS administrative work, a 5.0 / 72-review Google rating, and $91M+ in cumulative tax relief secured across 2,000+ resolved matters. No marketing claim of being a Florida-licensed firm — we are not. A factually accurate offer of federal tax representation, available to any St. Petersburg taxpayer, at the same standard we apply to a Los Angeles client. Our 100% remote workflow runs through a secure document portal — you never have to cross the Howard Frankland or the Sunshine Skyway.

Our seven-step process for St. Petersburg 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 with the IRS and Form DR-835 with the Florida DOR, register on the CAF system, and step in as the contact of record.

4

Transcript and CSED analysis

We pull IRS account transcripts via Form 8821, calculate each year's CSED under IRC § 6502, identify tolling events, and confirm any IRC § 7508A toll for hurricane disasters.

5

Strategy memo

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

6

Filing and negotiation

We file the operative document — Form 656, Form 433-A(OIC), Form 9423, Form 12153, a Florida DOR informal protest, or a DOAH petition through local counsel — and handle every IRS and Florida DOR contact.

7

Compliance monitoring

After resolution we monitor compliance through the OIC five-year terms or the IA term, file future returns, and prevent default.

Two collection clocks: federal CSED and Florida's parallel statutes

The IRS has ten years from the date of assessment to collect a federal tax under IRC § 6502. After the Collection Statute Expiration Date, the debt is extinguished by operation of law. The clock pauses (“tolls”) when an Offer in Compromise is pending, when a Collection Due Process petition is filed, during bankruptcy, when an installment agreement is requested, and when the taxpayer is outside the United States for six months or more. Hurricane-driven postponements under IRC § 7508A toll filing and payment deadlines but generally do not toll the collection statute itself — verify each year on transcript.

Florida runs separate state limitations rules. The Florida DOR generally has three years from the return due date to assess tax under Fla. Stat. § 95.091, extended to six years for substantial understatement or unreported sales, and without limit for fraud or unfiled returns. Once a tax warrant is recorded under Fla. Stat. § 213.731, collection runs for twenty years from the date of recording under Fla. Stat. § 95.091(1)(b). The federal ten-year CSED and Florida twenty-year warrant clock often produce a situation where the federal debt extinguishes years before the state warrant does — particularly relevant for St. Petersburg businesses with both an unpaid Form 941 federal balance and an open Florida sales-tax warrant. Pull both records and know both dates before agreeing to any payment plan or amended return that could restart a clock.

St. Petersburg tax authorities and venues

A working knowledge of the tribunals, agencies, and field offices around Pinellas County and Tampa Bay is what separates an answered Notice from a wage levy. Below is the working list our firm uses on every St. Petersburg matter.

Internal Revenue Service — Tampa TAC

The federal tax authority, at irs.gov. The nearest Taxpayer Assistance Center to St. Petersburg is the Tampa TAC at 3848 W Columbus Drive, Tampa FL 33607 — approximately 25 miles north across the Howard Frankland Bridge. Appointments are required for in-person service. Pull account transcripts via Form 8821 or through the practitioner e-services portal.

U.S. Tax Court — Tampa trial sessions

The U.S. Tax Court holds regular trial sessions in Tampa at the Sam M. Gibbons U.S. Courthouse, 801 N Florida Avenue, Tampa FL 33602 — the primary Florida trial city for the Tax Court and the venue for St. Petersburg cases. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline runs from the IRS Statutory Notice of Deficiency under IRC § 6213(a).

U.S. District Court — Middle District of Florida, Tampa 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 Middle District of Florida, Tampa Division, 801 N Florida Avenue, Tampa FL 33602, or in the U.S. Court of Federal Claims in Washington, D.C. St. Petersburg falls within the Tampa Division.

Florida Department of Revenue — Tampa Service Center

The state tax authority, at floridarevenue.com. Headquartered at 5050 W Tennessee Street, Tallahassee FL 32399. The Tampa Service Center at 4806 W Cypress Street, Tampa FL serves Pinellas, Hillsborough, Pasco, and Hernando taxpayers. Administers the 5.5% Florida Corporate Income Tax, 6% state sales tax, documentary stamp tax, reemployment tax, and the compromise authority under Fla. Stat. § 213.21.

Division of Administrative Hearings (DOAH)

The administrative forum for contested Florida tax assessments under Fla. Stat. ch. 120, seated at 1230 Apalachee Parkway, Tallahassee FL 32399. After a final Florida DOR Notice of Decision, a taxpayer has 60 days under Fla. Stat. § 72.011 to elect DOAH review or, alternatively, to challenge the assessment in circuit court (paying or bonding the tax). DOAH proceedings are conducted by Administrative Law Judges and produce a recommended order; the DOR issues the final order.

Pinellas County Tax Collector

The county tax authority for St. Petersburg. Main office at 315 Court Street, 3rd Floor, Clearwater FL 33756. Page: pinellastaxcollector.gov. Administers Pinellas County property-tax billing and collection, business tax receipts, tourist development tax, and other county-level revenue. NFTLs filed with the Pinellas County Clerk of the Circuit Court (same address) encumber St. Petersburg real property.

Pinellas County Property Appraiser

Office at 315 Court Street, Clearwater FL 33756. Sets assessed value, administers the Florida homestead exemption under Fla. Const. art. X, § 4 and the Save Our Homes 3% assessment cap under Fla. Const. art. VII, § 4(d). Value disputes are heard before the Pinellas Value Adjustment Board within 25 days of the TRIM notice.

City of St. Petersburg Finance Department

The municipal finance office, at 175 5th Street N, St. Petersburg FL 33701. Administers City of St. Petersburg business tax receipts, communications service tax remittance, and other city-level revenue separate from county property tax.

IRS Independent Office of Appeals

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

Taxpayer Advocate Service — Middle District of Florida

An independent organization within the IRS that helps when normal channels stall. The Tampa TAS office serves St. Petersburg and Pinellas County taxpayers across the Middle District of Florida. Page: taxpayeradvocate.irs.gov.

Speak with a tax attorney about your St. Petersburg matter

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

Call (800) 883-8301 Free Consultation

Frequently asked questions — St. Petersburg tax

Does Florida have a state income tax?

No state personal income tax. Fla. Const. art. VII, § 5 prohibits a state income tax on natural persons without a constitutional amendment. The Florida tax structure rests on a 5.5% Florida Corporate Income Tax under Fla. Stat. ch. 220 (with the first $50,000 of net income exempt and pass-through entities generally exempt), 6% state sales and use tax plus local discretionary surtaxes (7% combined in St. Petersburg with the Pinellas 1% add-on), documentary stamp tax under Fla. Stat. ch. 201, reemployment (unemployment) tax under Fla. Stat. ch. 443, and a small list of excise taxes. For most individual St. Petersburg taxpayers, the entire income-tax exposure is federal.

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

The U.S. Tax Court holds regular trial sessions in Tampa at the Sam M. Gibbons U.S. Courthouse, 801 N Florida Avenue — approximately 25 miles north of downtown St. Petersburg across the Howard Frankland Bridge. Tampa is the primary Florida trial city for the Tax Court. A taxpayer anywhere in the Middle District of Florida (Pinellas, Hillsborough, Pasco, Hernando, Manatee, Sarasota, and surrounding counties) can request the Tampa trial location when filing the Tax Court petition. Petitions are filed electronically through DAWSON at ustaxcourt.gov; the 90-day deadline from the IRS Statutory Notice of Deficiency under IRC § 6213(a) is jurisdictional — a single day late and the federal assessment becomes final.

I work at Raymond James — how do RSU and ISO grants generate a federal tax bill?

Raymond James RSU vest events are taxed as ordinary W-2 income at fair market value on the vest date. The 22% federal supplemental withholding rate is well below a 32%, 35%, or 37% marginal rate, so a six-figure RSU vest routinely under-withholds by tens of thousands of dollars. ISO exercises that are held past year-end trigger AMT under IRC § 55 on the bargain element; disqualifying dispositions convert ISO gain back to ordinary income. Because Florida has no PIT, every adjustment lands at the federal level. We rebuild the W-4, set up Form 1040-ES under IRC § 6654, and resolve any back balance through a streamlined installment agreement, partial-pay IA, or Offer in Compromise depending on Reasonable Collection Potential. For partner-level Raymond James advisors, IRC § 199A specified-service-trade-or-business analysis is layered on — investment management is statutorily excluded from the QBI deduction under Treas. Reg. § 1.199A-5(b)(2)(xi).

I work at Jabil — what tax issues do I see most often?

Jabil's Fortune 500 electronic manufacturing services workforce sees three recurring federal patterns. First, RSU underwithholding at the 22% supplemental rate, same as Raymond James. Second, ISO exercises producing AMT under IRC § 55. Third, for Schedule C 1099 supply-chain vendors and consultants, the post-TCJA five-year capitalization rule for domestic research and experimentation expenses under IRC § 174 changed the entire cash-flow profile for engineering and product-development contractors — a 2025 deduction is no longer immediate and must be amortized. We unwind misfilings and rebuild the depreciation and amortization schedules.

How do I challenge a Florida DOR sales-tax assessment?

A Florida DOR audit produces a Notice of Intent to Make Audit Changes (often called the “DR-840”), followed by a Notice of Proposed Assessment if the taxpayer does not resolve at the audit level. The Proposed Assessment opens a 60-day window to file an informal protest with the Florida DOR Technical Assistance and Dispute Resolution group. If the protest is denied, the DOR issues a Notice of Decision (or Notice of Reconsideration). Under Fla. Stat. § 72.011, the taxpayer then has 60 days to elect either a DOAH administrative proceeding under Fla. Stat. ch. 120 or a circuit-court action (paying or bonding the contested tax). We handle the protest stage directly under Form DR-835 and coordinate Florida counsel for the DOAH or circuit-court stage.

What is Florida's collection statute of limitations?

Fla. Stat. § 95.091 gives the Florida DOR three years from a return's due date to assess tax (six years for substantial understatement, with no limit for fraud or unfiled returns). Once a Florida tax warrant is recorded under Fla. Stat. § 213.731, collection runs for twenty years from the date of recording. The federal CSED under IRC § 6502 is a separate ten-year clock running from the federal assessment date. A St. Petersburg taxpayer with both a federal payroll-tax balance and a Florida sales-tax warrant routinely sees the federal debt extinguish years before the state warrant does.

My St. Pete Beach or Treasure Island property took hurricane damage — how do I deduct the loss?

For Hurricanes Ian (2022), Idalia (2023), Helene (2024), and Milton (2024), all were federally declared disasters, which means IRC § 165(h) personal casualty losses are available for the unreimbursed portion above the $100 per-event floor and 10% of AGI threshold. Election under IRC § 165(i) allows the loss to be claimed on the prior year's return for faster refund. IRC § 1033 defers gain when insurance or FEMA proceeds exceed basis, provided qualifying replacement property is acquired within the statutory window (two years for personal-use, four years for business). IRC § 7508A tolls filing and payment deadlines for taxpayers in the disaster area. We coordinate the basis-recovery, gain-deferral, and timing pieces against the insurance settlement — particularly important for the heavy storm-surge zones along the Pinellas barrier islands and Shore Acres.

I own a short-term rental on St. Pete Beach or Madeira Beach — what do I report?

Two layers. Federally, the seven-day average rental period rule under Treas. Reg. § 1.469-1T(e)(3)(ii) takes the activity out of the rental category and into the trade-or-business category, with passive-activity rules under IRC § 469 and material-participation testing. IRC § 280A vacation-home limitations apply when personal use exceeds the greater of 14 days or 10% of rental days. Schedule C vs Schedule E classification turns on whether substantial services are provided. On the state side, Florida transient rental tax under Fla. Stat. § 212.03 applies (6% state plus Pinellas tourist development tax for a combined 13% in Pinellas on rentals of six months or less). Local zoning and registration rules in St. Pete Beach, Treasure Island, and Madeira Beach add a third layer.

Can a California-Bar-admitted attorney represent me in St. Petersburg?

For federal IRS matters — yes. The IRS accepts Form 2848 Power of Attorney from any attorney in good standing with any state bar. The U.S. Tax Court is a single federal court with nationwide jurisdiction; an attorney admitted to that court may represent a taxpayer at any Tax Court trial location, including Tampa, the primary Florida trial city serving St. Petersburg. For Florida DOR administrative work, we file Form DR-835 Power of Attorney and handle the matter remotely. For DOAH litigation, Florida circuit-court actions under Fla. Stat. § 72.011, or appeals to the Florida District Courts of Appeal, we co-counsel with locally admitted Florida attorneys. Most engagements — audit defense, OIC, IA, levy release, FBAR disclosure, Tax Court — are federal and stay entirely with our firm.

What if I have unfiled returns going back several years?

The IRS Voluntary Filing Compliance policy and IRM 5.1.11.6 generally require the last six years of returns to bring a taxpayer back into compliance. Filing prior-year returns is the first step before any OIC, IA, or CNC request — IRC § 7122(d) compliance is a prerequisite for a federal Offer. Refunds claimed on returns filed more than three years after the original due date are time-barred under IRC § 6511(b)(2). For St. Petersburg taxpayers affected by Hurricanes Ian, Idalia, Helene, or Milton, IRC § 7508A may have tolled certain deadlines materially — verify each year on transcript before treating any year as time-barred.

Can the IRS levy my St. Petersburg 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 Raymond James Bank, Truist, Bank of America, Wells Fargo, Fifth Third, or any Florida-licensed institution and serve wage levies on St. Pete employers. A timely Form 12153 CDP request halts collection while the case is reviewed by Appeals. After a CDP determination, the taxpayer has 30 days to petition the U.S. Tax Court under IRC § 6330(d)(1). Florida issues parallel state tax warrants under Fla. Stat. § 213.731 that work similarly through Pinellas County Clerk recording.

I'm a Tampa Bay Rays player living in St. Pete — how does jock tax work?

Florida domicile gives you a zero state personal income tax on Florida-source income, which is the planning value for Rays, Buccaneers, and Lightning players. But away games create source-state income subject to the destination state's nonresident allocation rules. The standard allocation is duty days — the proportion of total duty days spent in the source state, multiplied by total compensation. California, New York, and Illinois are aggressive enforcers. We coordinate the duty-day calculation, document the Florida domicile (driver license, voter registration, primary residence at Snell Isle or downtown St. Pete, Florida physician records, Florida business interests), handle MLB minor-leaguer 1099 endorsement income, and resolve any federal underpayment from the source-state withholding gap under IRC § 6654.

I'm a U.S. citizen with family banking accounts in Cuba, Puerto Rico, or the Philippines — what do I need to report?

FinCEN Form 114 (the FBAR) is required when aggregate foreign-account balances exceed $10,000 at any point in the year, under 31 U.S.C. § 5314. FATCA Form 8938 has higher thresholds and is filed with Form 1040. For unfiled prior years, the IRS Streamlined Filing Compliance Procedures (domestic or foreign) cure non-willful violations with a single-tier 5% miscellaneous offshore penalty (domestic version) or zero penalty (foreign version), provided the taxpayer certifies non-willfulness. Willful conduct triggers the 50%-per-year penalty, capped reasonably under Bittner v. United States, 598 U.S. 85 (2023), but only for non-willful cases. Puerto Rico is U.S. domestic for FBAR purposes; Cuba and the Philippines are foreign. We sort the classification, the disclosure path, and the income-side cleanup.

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

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

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. Florida state collection follows a similar pattern: a Form DR-835 routes state contact, and a pending compromise or stipulated time payment pauses warrant enforcement.

About the author

This page was written and reviewed by Parham Khorsandi, Esq., Managing Attorney of Victory Tax Lawyers, LLP. Cal Bar #266658. Admitted to practice before the United States Tax Court. Mr. Khorsandi has resolved over 2,000 federal tax matters and secured more than $91 million in tax relief for clients across all 50 states.

Page last reviewed: . Editorial standard: every federal-statute citation links to law.cornell.edu (Legal Information Institute, Cornell Law School). Every Florida statute citation references the Florida Statutes as published by the Florida Legislature. 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 Florida Department of Revenue, the U.S. Tax Court, the Division 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 Florida; where a Florida state-court appearance, DOAH proceeding, or appeal to a Florida District Court of Appeal is required, the firm associates with locally admitted Florida counsel.

IRS Circular 230 Disclosure: The discussion of U.S. federal tax issues on this page is not intended or written to be used, and cannot be used, for the purpose of avoiding penalties imposed under the Internal Revenue Code or for promoting, marketing, or recommending to another party any tax-related matters addressed. For specific tax advice, consult independent tax counsel.

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